Enforcement Release: June 1, 2026
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
FTI Consulting, Inc. (“FTI”), a Washington D.C.-based international consulting and advisory firm, has agreed to pay $1,050,000 to settle its potential civil liability for apparent violations of OFAC sanctions targeting Russia’s financial sector. Between April 2019 and May 2021, FTI indirectly dealt in prohibited debt of VTB Bank OAO (“VTB”), a Russian state-owned bank, on six occasions. These prohibited dealings occurred when FTI extended debt of more than 14 days maturity to VTB by indirectly issuing invoices to VTB that went unpaid or were paid long past the expiration of the permissible 14-day tenor. All the while, even when invoices remained unpaid for long periods, FTI continued to perform valuable services for the benefit of...
1) From a legal basis of violations perspective, this enforcement release is precedential in a number of ways. First, it is the only case as of the date of publication in which OFAC articulates (or gives an example of) what it means to “indirectly” deal in “new debt” of a person subject to the new debt prohibition. Notably, SSI Directive 1 does not specify that the prohibition on dealings in “new debt” extent to “indirect” dealings in “new debt,” but OFAC bases its penalty on the “the foundational principle, adopted broadly throughout OFAC’s regulations and the relevant restrictions here, that it is prohibited to do indirectly what one cannot do directly.” Compare FAQ # 72 (“You cannot do something indirectly that you would not be able to do directly”). This however appears to be the first time in which OFAC characterizes the prohibition on...