$3.77 Million Lesson: How Dealing with Sanctioned Persons Destroys Business and Reputation
On February 25, 2026, the Office of Foreign Assets Control (OFAC) announced that a U.S. individual agreed to pay $3,777,000 to settle potential civil liability for 20 apparent violations of U.S. sanctions on Syria. The case sends a clear message: even indirect managerial involvement with sanctioned persons or entities can result in severe financial and reputational consequences even years...
OFAC Specific License Application: Submission, Review, and Outcome
On July 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that its Licensing Hotline is moving to a new online platform dedicated to handling communications regarding the submission and processing of OFAC specific license applications.
Previously, applicants needed to call OFAC for licensing inquiries, a process that was often difficult and...
Suleiman Kerimov, GVA Capital Ltd, and OFAC
On June 12, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a notice on its website announcing the imposition of a $216 million fine on GVA Capital Ltd. for violating OFAC sanctions against Russia and for failing to comply with an OFAC subpoena during the investigation of the case. The announcement also prominently featured Russian oligarch...
OFAC Request for Additional Information: What Does It Mean?
Introduction
A request from the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury for additional information or supporting documents is a fairly common occurrence when dealing with this agency. Such requests often arise, for example, when submitting an application to OFAC for a license or removal from the U.S. sanctions list.
There are also situations where...
You’ve Got OFAC Subpoena: What Should You Do?
You’ve Got an OFAC Subpoena: What Does It Mean?
An OFAC Subpoena is an official request, or rather, demand from the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury, to provide specific documents, materials, and information in compliance with American sanction policies.
Accompanying the OFAC subpoena is a cover letter explaining why you have received the...