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Between April 2018 and June 2022, the settling individual — a former US government official and attorney — acted as fiduciary and trustee of a US-based family trust established for the benefit of a Russian national who had been designated on OFAC's Specially Designated Nationals (SDN) List under Executive Order 13662 (Ukraine-Related Sanctions Regulations, 31 C.F.R. Part 589) and, later, under Executive Order 14024 (Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. Part 587). In that fiduciary capacity, the individual committed 122 discrete apparent violations by managing trust assets, executing distributions from trust accounts, and facilitating financial transactions on behalf of the blocked principal without OFAC authorisation — each administrative event constituting a separate dealing in blocked property and/or provision of a prohibited service.
Settlement terms: USD 1,092,000 civil monetary penalty, settled as a single lump payment. OFAC assessed the violations as non-egregious (no deliberate structuring to evade OFAC review, no third-country laundering relay). The individual cooperated substantially with the investigation, providing documents and access beyond what was compelled, which OFAC credited as a significant mitigating factor reducing the penalty below the applicable base amount.
Sanctions programs implicated: Ukraine-Related Sanctions Regulations (URSR, 31 C.F.R. Part 589) under EO 13662 and Russian Harmful Foreign Activities Sanctions Regulations (RuHSR, 31 C.F.R. Part 587) under EO 14024. The 2018–2022 violation period is notable because it straddles the pre– and post–February 2022 mass-designation wave: the original SDN designation under EO 13662 occurred well before the February 2022 invasion of Ukraine, establishing that fiduciary obligations to blocked persons attach at designation and cannot be warehoused pending geopolitical recalibration.
Individual-professional-fiduciary precedent. This is OFAC's first published civil enforcement action in the Russian-oligarch-asset context against an individual in their personal fiduciary / professional-services capacity. It is distinct from:
VC fund; corporate respondent.
fund administrator; corporate respondent.
This settlement establishes that US-based trustees, family-office principals, attorneys, accountants, and other professionals acting in a fiduciary capacity on behalf of SDN-listed Russian nationals face direct personal civil liability — not merely derivative compliance risk through their institutional employer.
Gatekeeper-profession compliance implications. OFAC's 2025 Five Key Takeaways synthesis (Sidley Austin, February 2026) identifies this settlement as evidence that OFAC views "gatekeeper" professions — investment advisers, accountants, attorneys, and trust-and-corporate- service providers — as squarely within its enforcement perimeter for Russia-related programs. The practical upside for compliance counsel is that the 122-violation count provides a granular quantum basis for pricing exposure: each discrete trust-administration event (bank wire, distribution authorisation, account management instruction) constitutes a separate apparent violation, so a four-year fiduciary engagement with a blocked-person trust can accumulate triple-digit violation counts even absent egregious or structured evasion.
Dual-rail Russian-oligarch enforcement architecture. Together with IPI Partners (December 2025), this settlement completes a dual-rail December 2025 enforcement wave: one action targeting the institutional administrator (IPI Partners) and one targeting the individual fiduciary / professional trustee. The dual-rail structure signals that OFAC is pursuing Russian-oligarch-asset enforcement simultaneously through the corporate compliance pathway (institutional respondents) and the personal-liability pathway (individual professional-services respondents), closing the gap that historically allowed professional intermediaries to absorb institutional liability while preserving individual professional indemnity.
Structural parallel to Syrian-individual settlement (February 2026, 2026-02-25-us-ofac-individual-syrian-sanctions-real-estate-settlement): that action addressed an individual managing real-estate assets for a sanctioned Syrian principal. Together the two individual-fiduciary settlements across Russia + Syria sanction perimeters establish a coherent cross-program pattern — OFAC is not limiting individual-fiduciary enforcement to the Russia program but applying the same theory consistently across multi-program individual gatekeepers.
private-bank trust departments with pre-2022 client relationships involving Russian HNW nationals now face a clear precedent quantifying personal civil exposure at the individual level — not merely through institutional employer channels.
EO 14024 mass-designation wave does not reset or restart fiduciary exposure clocks — obligations under EO 13662 designations already existed from the time of original SDN listing.
relationships will need to address the individual personal liability exposure alongside the institutional employer's compliance program — an escalating dual-track exposure analysis.
in future waves): the professional-services perimeter is expanding beyond financial intermediaries to the full gatekeeper stack.
disciplinary proceedings (the individual is described as a "former US government official and attorney").
establishes a per-event pricing floor for future individual-fiduciary enforcement actions or whether it reflects bespoke mitigation specific to this respondent's cooperation level.
of professional-services fiduciaries in the Russia-sanctions context, analogous to the investment-adviser guidance it issued following the GVA Capital action.