Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 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.

On 30 July 2025 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, published a civil monetary penalty of £300,000 against Markom Management Limited (MML UK), a London-incorporated provider of corporate-services and management functions to its parent Markom Management Cyprus. The penalty (decision dated 10 January 2025) relates to MML UK instructing the transfer of £416,590.92 from a Moscow-based bank account of its parent's client to a person designated under an EU Regulation 269/2014 asset freeze (Russia/Crimea-related), at a time when MML UK had knowledge of the recipient's designated status. OFSI initially proposed £400,000; MML's representations secured a reduction to £300,000, which was subsequently upheld on ministerial review under s.147 of the Policing and Crime Act 2017. At the time of publication this was the third-largest OFSI civil monetary penalty imposed since the powers were introduced under Part 8 of the Policing and Crime Act 2017, and the twelfth use of those powers in total.

OFSI imposed a £465,000 civil monetary penalty on Herbert Smith Freehills CIS LLP (the firm's Moscow subsidiary, "HSF Moscow") for six payments totalling £3,932,392.10 made to three Russia-designated persons — Alfa-Bank JSC, PJSC Sovcombank, and PJSC Sberbank — during the wind-down of the Moscow office in May 2022, in breach of the Russia (Sanctions) (EU Exit) Regulations 2019. The penalty is the first OFSI enforcement action against the legal-services sector and the first against a Big Law firm; OFSI signalled further professional-services enforcement is in the pipeline. HSF London's voluntary disclosure and full cooperation secured a 50% penalty reduction from an initial £930,000 basis.

Switzerland's Federal Council amended the Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) to align with the EU's eighth sanctions package, effective 6pm on 23 November 2022. The amendment creates the Swiss legal basis for an oil price-cap mechanism — banning maritime transport to third countries of Russian-origin crude oil and petroleum products unless purchased at or below a price cap to be set later (the G7/EU $60/bbl cap followed on 3 December 2022; see the companion US OFAC determination of 2022-12-05). It also extends import/export restrictions to additional iron and steel products and aerospace goods, bans the provision of IT, engineering, architecture and legal services to the Russian government and Russian companies, bans Swiss nationals from holding board seats at certain Russian state-owned companies, fully bans crypto-asset wallet/account/custody services to Russian persons regardless of value, and adopts an arms embargo against Russia (extended in part to Ukraine for reasons of Swiss neutrality).

On 6 October 2022 the Council of the European Union adopted Council Regulation (EU) 2022/1904, amending Regulation (EU) No 833/2014, as the EU's eighth package of restrictive measures against Russia. It entered into force 7 October 2022. The regulation's headline measure creates the legal basis for an oil price-cap mechanism: a ban on maritime transport to third countries of Russian-origin crude oil and petroleum products, becoming operational once the Council sets an actual cap level by a separate decision (the G7/EU $60/bbl cap followed on 3 December 2022). The package also expands import bans on steel products (phased through 2024), firearms and ammunition, wood pulp and paper, and certain chemicals, cosmetics and jewellery materials; extends export bans on aviation-sector goods; bans the provision of architectural, engineering, IT-consultancy and legal advisory services to the Russian government and Russian companies; and imposes restrictions on Russian-flagged vessels at the Russian Maritime Register.

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.