US OFAC Settlement with Individual — Syrian Sanctions Regulations (Real Estate Managerial Services)

Mechanism

Between January 2018 and December 2021, a U.S. national provided managerial services to four Syrian real-estate companies while serving as an officer and board member. The services included reviewing and signing financial statements, approving operational and employee expenses, and supervising the collection of service fees — each constituting a prohibited export of services to Syria under the Syrian Sanctions Regulations (SSR, 31 CFR Part 542, implemented under IEEPA and the International Emergency Economic Powers Act authority extending from Executive Order 13338 of 2004 and successors).

OFAC identified 20 apparent violations. Under the IEEPA civil monetary penalty matrix:

• Egregious, not voluntarily self-disclosed: base statutory maximum per violation applies
• Settlement at 10× the per-violation IEEPA base = $3,777,000 total ($188,850 per violation)

Aggravating factors: 1. Reckless disregard for U.S. sanctions obligations 2. Actual knowledge that the companies were organised and located in Syria 3. Scheme spanning four years across 20 discrete apparent violations

Mitigating factors: 1. No prior OFAC penalty notice or finding of violation in the preceding five years

Downstream implications

• Personal-liability precedent: This is a rare natural-person OFAC civil enforcement action —

the overwhelming majority of OFAC civil settlements target corporate entities. The $3.777M personal settlement signals that OFAC will pursue individual executives and board members for sanctions exposure, not just the corporate vehicle.

• Board/officer-role exposure: Any U.S. person serving as officer, director, or board member

of a company in or materially linked to a sanctions jurisdiction faces personal liability for services rendered in that fiduciary capacity — including ostensibly administrative acts such as signing financial statements or approving expense claims. The definition of "managerial services" in OFAC enforcement is now quantified at $188,850/violation.

• MENA real-estate compliance repricing: U.S. expatriate executives and dual nationals holding

directorships in MENA real-estate vehicles with Syrian-linked LPs, subsidiaries, or sister-companies should treat this settlement as a concrete personal compliance-cost floor.

• Historical Syria sanctions scope note: The violations occurred under the legacy SSR

(31 CFR Part 542), which imposed a comprehensive country-level embargo. The SSR was restructured into the PAARSS program (31 CFR Part 569) following the fall of the Assad regime in December 2024; PAARSS targets Assad-network actors and Iran-proxy networks rather than imposing a blanket embargo. Conduct generating this settlement would likely not constitute violations under current post-Assad rules — but OFAC enforced the law as it existed at the time of the violations.

Open questions

• The individual's identity is not disclosed in the enforcement release — OFAC withheld the name,

which is unusual relative to most corporate settlements. Whether natural-person anonymisation is a standard OFAC policy or circumstance-specific is unclear.

• Whether OFAC pursued or will pursue other officers or directors of the same four Syrian

real-estate companies who may have provided analogous managerial services.

• The luxury real-estate developments referenced in the notice have not been identified by name;

their ownership structure and whether any designated parties (Assad-network SDNs) held beneficial interests in those projects is not disclosed.