The U.S. Treasury’s Office of Foreign Assets Control (OFAC) has announced a $1,092,000 settlement with a U.S. attorney who served as fiduciary for the family trust of a sanctioned Russian oligarch. Although the conduct occurred between 2018 and 2022, much of it unfolded after the oligarch’s designation in 2018, when all of his property and interests became blocked. OFAC found that the attorney continued to authorize transfers, payments, and other trust activities that effectively allowed the Russian oligarch to retain control over the assets.

The case illustrates how professional “gatekeepers”, lawyers, advisors, trustees, and corporate service providers, can unintentionally enable sanctions evasion when they fail to fully assess the practical influence a sanctioned party retains over an asset. OFAC noted that even though the attorney relied on outside legal advice, they should have recognized that a close associate of the Russian oligarch continued to act as his proxy, signaling that the oligarch maintained an interest in the trust. These actions resulted in 122 apparent violations of Russia-related sanctions. OFAC treated the violations as non-egregious and acknowledged the attorney’s cooperation.

The key takeaway from this case is clear: complex legal structures do not protect U.S. persons from liability when a sanctioned individual continues to exert hidden influence. It underscores that sanctions compliance requires more than checking formal boxes. It calls for a clear-eyed understanding of economic reality, especially when dealing with trusts and other structures that can obscure ownership and control.