
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued four enforcement actions during the first half of this year, two in January under former President Biden and two in June under President Trump. These actions, described below, underscore the ongoing relevance of sanctions compliance programs in the Trump era.
2025 Enforcement Actions
January 16, 2025: OFAC entered into a $1,076,923 settlement with the Florida-based real estate company, Family International Realty LLC (“Family International” or “the Company”), and its natural U.S. person owner (“the Owner”) for apparent violations of OFAC’s Ukraine-/Russia-related sanctions. The Company was alleged to have willfully evaded OFAC’s Ukraine-/Russia-related sanctions by transferring ownership of three luxury condominiums owned by two sanctioned Russian oligarchs to their non-sanctioned family members and their corresponding shell companies. During the investigation, OFAC uncovered telephone communications between the Owner and the sanctioned individuals demonstrating the Owner’s knowledge of the oligarchs’ sanctioned status. The Owner is also alleged to have coordinated with a law firm to facilitate the transfer of ownership. As a result, OFAC determined that the Company’s conduct was egregious and not voluntarily self-disclosed. OFAC’s corresponding Enforcement Release underscores that gatekeepers – including investors, attorneys, and other service providers – may be used to conceal or further sanctions evasion. Entities should conduct gatekeeper-related due diligence to ensure that their actions comply with sanctions regulations.