Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

On 1 June 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) announced that FTI Consulting, Inc. (NYSE: FCN), a global business-advisory and expert-witness firm, agreed to pay $1,050,000 to settle apparent civil liability for six indirect dealings in prohibited debt of VTB Bank OAO between April 2019 and May 2021 — constituting violations of the Russia Harmful Foreign Activities Sanctions Regulations (RuHSR) and the then-applicable Directive 1 debt-tenor restrictions. FTI had been engaged via an intermediary global law firm to provide expert economic consulting services supporting VTB in Singapore litigation; invoices issued through that intermediary went unpaid or were paid far beyond the permissible 14-day tenor, extending prohibited debt on six occasions totalling approximately $353,862. OFAC determined the conduct was non-egregious and not voluntarily self-disclosed, and imposed a penalty of $1,050,000 — double the $525,000 base penalty — citing the foundational principle that a party may not do indirectly what it cannot do directly.

OFAC settled civil liability of USD 1,092,000 with an unnamed individual (a former US government official and attorney) for 122 apparent violations of Russia-related sanctions programs spanning April 2018 to June 2022. The individual served as fiduciary and trustee of a US-based family trust established for the benefit of a sanctioned Russian oligarch (SDN-listed under EO 13662 and EO 14024) and in that capacity dealt in the blocked property of — and provided prohibited trust-administration services to — the oligarch without OFAC authorisation. OFAC assessed the conduct as non-egregious and not voluntarily self-disclosed, but credited substantial cooperation in fixing the penalty below the base amount.

The US Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (31 CFR Part 515) effective 24 September 2020 to further deny the Cuban regime revenue. The rule added a new prohibition on lodging at any property on the State Department's Cuba Prohibited Accommodations List (PAL) and removed the general licence permitting travellers to import Cuban-origin alcohol and tobacco products as accompanied baggage. It also narrowed the professional meetings and conferences general licence (515.564) and the public performances, clinics, workshops, competitions, and exhibitions general licence (515.575) to exclude Cuba-related activities, closing gaps exploited under earlier travel-authorisation categories.