Who was sanctioned, and for what?

Consulting firm FTI Consulting, Inc. of Washington, D.C. is paying USD 1,050,000 under a settlement with OFAC for apparent violations of the Russia financial sector sanctions. According to OFAC's findings, between April 2019 and May 2021 FTI indirectly extended prohibited debt on six occasions to a Russian state-owned bank subject to Directive 1 under Executive Order 13662: invoices remained unpaid beyond the permitted 14 days or were paid long afterwards while FTI continued to provide services. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 525,000. The settlement amount is above the base penalty; OFAC cited in particular the anticipated impact on future compliance by similarly situated firms. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "FTI Consulting, Inc., a Global Business Advisory Firm, Settles with OFAC for $1,050,000 Related to Apparent Violations of Dealing in Prohibited Debt of Sanctioned Russian Bank", 1 June 2026, https://ofac.treasury.gov/media/935651/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. §§ 589.202, 589.213 i. V. m. Directive 1 zu E.O. 13662 (sechs mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

1 Jun 2026

Original amount 1,050,000 USD, converted at the ECB reference rate of 1 Jun 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

School and sports academy IMG Academy, LLC of Bradenton, Florida, is paying USD 1,720,000 under a settlement with OFAC for apparent violations of the counternarcotics sanctions. According to OFAC's findings, between 2019 and 2025 IMG Academy entered into tuition agreements for the children of two individuals on the SDN List because of their ties to a sanctioned Mexican drug cartel and processed the related payments; 89 dealings were involved in total. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed because an investigation was already under way when the academy reported them; the settlement amount equals the base penalty. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "IMG Academy, LLC Settles with OFAC for $1.7 Million Related to Apparent Violations of Counternarcotics Sanctions", 12 February 2026, https://ofac.treasury.gov/media/935006/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. § 598.202 (89 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

12 Feb 2026

Original amount 1,720,000 USD, converted at the ECB reference rate of 12 Feb 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

A UK exporter not named by HMRC paid a compound settlement of £1,160,725.67 in May 2025 over alleged breaches of the Russia sanctions. According to HMRC, it had made goods available to Russia. According to HMRC, it was at the time of the notice the largest settlement the authority had concluded for a breach of the Russia sanctions; among the lessons, HMRC highlights the risk of supplying Russian companies with operations in third countries.

Authority / court

HM Revenue & Customs (HMRC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Russia (Sanctions) (EU Exit) Regulations 2019

Action

Fine

Status of proceedings

final

Sector

Other

Published

8 Jul 2025

Original amount 1,160,725.67 GBP, converted at the ECB reference rate of 8 Jul 2025.

Checked against the official source on 3 Oct 2026 · Direct link

On 14 March 2025 OFSI published a report on breaches by three UK charities – Sahara Hands, Peculiar Peoples' Palace Ministries and Impact Planet – of information requirements under counter-terrorism sanctions law; OFSI did not impose a monetary penalty. According to OFSI's findings, the organisations had failed without reasonable excuse to provide information in response to a formal request, despite three letters. OFSI made clear that this concerns an information offence only and that it holds no information indicating any further breach of the sanctions regulations. OFSI considers it possible that out-of-date contact details on the Charity Commission register played a role, but did not treat this as mitigating. Type of measure: Breach published by OFSI instead of a monetary penalty (disclosure under s. 149(3) PACA 2017). The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Disclosure notice: 14 March 2025", 14 March 2025, https://www.gov.uk/government/publications/disclosure-notice-14-march-2025. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019, reg. 36(6); Veröffentlichung nach s. 149(3) Policing and Crime Act 2017

Action

Other

Status of proceedings

unknown

Sector

Other

Published

14 Mar 2025

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

Californian musical instrument manufacturer Córdoba Music Group LLC is paying USD 41,591 under a settlement with OFAC for apparent violations of the Iran sanctions. According to OFAC's findings, between November 2019 and March 2022 the company made nine shipments of instruments and accessories worth USD 118,831 to a trading company in Dubai, knowing that the goods were destined for an Iranian distributor. According to OFAC, the company apparently did not realise, partly owing to a lack of compliance training, that indirect exports to Iran were prohibited. This came to light after the company was acquired by a new owner. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 59,416. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Córdoba Music Group LLC Settles with OFAC for $41,591 Related to Apparent Violations of the Iranian Transactions and Sanctions Regulations", 18 December 2024, https://ofac.treasury.gov/media/933726/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204(a) (neun Lieferungen); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

18 Dec 2024

Original amount 41,591 USD, converted at the ECB reference rate of 18 Dec 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

On 11 November 2024 OFSI imposed a monetary penalty of GBP 465,000 on Herbert Smith Freehills CIS LLP, the Moscow office of an international law firm; without the 50 per cent discount for voluntary disclosure it would have been GBP 930,000, according to OFSI. According to OFSI's findings, between 25 and 31 May 2022 the entity made six payments totalling GBP 3,932,392.10 to three designated Russian banks, partly in the course of closing the office. OFSI identified insufficient checks and a lack of sanctions screening of the payments, as well as haste in winding down, as causes. OFSI made no findings against the London parent. A ministerial review upheld the penalty on 14 February 2025, and on 14 March 2025 the London parent agreed to pay the penalty in full on the entity's behalf. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Herbert Smith Freehills CIS LLP Moscow", 20 March 2025, https://www.gov.uk/government/publications/penalty-notice-20-march-2025. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019; Geldbuße nach section 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Other

Published

20 Mar 2025

Original amount 465,000 GBP, converted at the ECB reference rate of 11 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

Vietnamese holding company Vietnam Beverage Company Limited is paying USD 860,000 under a settlement with OFAC on behalf of two subsidiaries for apparent violations of the North Korea sanctions. According to OFAC's findings, between April 2016 and October 2018 the beverage subsidiaries received payments of around USD 1,141,547 through US financial institutions on 43 occasions for the sale of alcoholic beverages to North Korea, thereby causing those institutions to export financial services to North Korea. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed but credited its cooperation and its proactive notification of internal findings; the base penalty was USD 1,720,000. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Vietnam Beverage Company Limited settles with OFAC for $860,000 for Apparent Violations of the North Korea Sanctions Regulations", 17 October 2024, https://ofac.treasury.gov/media/933501/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

North Korea Sanctions Regulations, 31 C.F.R. § 510.212 (43 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

17 Oct 2024

Original amount 860,000 USD, converted at the ECB reference rate of 17 Oct 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

At the end of 2021, a company based in Amsterdam paid out a dividend of around 18 million EUR to a Russian shareholder behind which there was a sanctioned person, repaid a loan to a listed Russian company in 2019 and did not freeze shares and voting rights; in addition, a gatekeeper was misinformed. In a settlement (transactie) with the Dutch Public Prosecution Service (Openbaar Ministerie), the company paid 195,000 EUR.

Authority / court

Openbaar Ministerie (Staatsanwaltschaft der Niederlande)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Sanctiewet 1977 i. V. m. EU-Finanzsanktionen gegen Russland (seit 2014)

Action

Fine

Status of proceedings

final

Sector

Other

Liability of senior managers

Measures against individuals are not reported here.

Published

23 Sep 2024

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 23 Sep 2026 · Direct link

A London-based tobacco group is paying USD 508,612,492, the statutory maximum, under a settlement with OFAC for apparent violations of the North Korea sanctions and the weapons of mass destruction proliferators sanctions. According to OFAC's findings, the group entered into a conspiracy to supply tobacco products to North Korea and to route payments for them through the US financial system; around USD 251.6 million flowed in this way between 2009 and 2016. In addition, its Singapore subsidiary received US dollar payments via US banks for cigarette sales to the North Korean embassy in Singapore. As a result, US banks processed payments involving blocked North Korean banks. OFAC treated the apparent violations as egregious and not voluntarily self-disclosed. The settlement was concluded alongside a resolution with the DOJ; USD 503,263,807 is deemed satisfied by the payment there and USD 5,348,685 is payable to the Treasury. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. § 544.205(b) (ein mutmaßlicher Verstoß); North Korea Sanctions Regulations, 31 C.F.R. § 510.212 (15 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

25 Apr 2023

Original amount 508,612,492 USD, converted at the ECB reference rate of 17 Apr 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 17 Apr 2025 · Direct link

An Indian tobacco manufacturer based in Mumbai is paying USD 332,500 under a settlement with OFAC for five apparent violations of the North Korea sanctions. According to OFAC's findings, in 2017 the company indirectly supplied tobacco to North Korea through intermediaries and had the payments remitted in US dollars via intermediaries in third countries. This obscured the connection to North Korea and caused US banks to process the payments. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 475,000. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

North Korea Sanctions Regulations, 31 C.F.R. § 510.212 (Veranlassung von Verstößen gegen §§ 510.206, 510.211 durch US-Banken; fünf mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

1 Mar 2023

Original amount 332,500 USD, converted at the ECB reference rate of 1 Mar 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 1 Mar 2025 · Direct link

A Californian cosmetics company is paying USD 3,334,286 under a settlement with OFAC for an apparent violation of the Iran sanctions. According to OFAC's findings, for around eight years until 2018 the company took part in a conspiracy with an Iranian and an Emirati distributor to supply goods and services from the United States to Iran without authorisation, involving at least 62 exports worth around USD 11.1 million. OFAC treated the apparent violation as egregious but voluntarily self-disclosed following a change of ownership; the base penalty was USD 11,114,287. OFAC signed the settlement agreement with the company on 2 November 2022 and published it on 17 May 2023. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560, insbesondere § 560.203(b) (Verabredung zur Umgehung); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Liability of senior managers

Measures against individuals are not reported here.

Published

17 May 2023

Original amount 3,334,286 USD, converted at the ECB reference rate of 2 Nov 2022.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 2 Nov 2024 · Direct link