Enforcement Release: Family International Realty LLC and its Owner

Date issued: Jan. 16 2025

Last substantive commentary amendment:
Apr. 03 2026

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TURBOFAC Commentary (1013 words)

Notes:

[2026-04-04 update - read in light of OFAC's 2026 Sham Transactions Guidance. The below has not yet been updated to reflect the issuance of the Sham Transactions Guidance].

1) From a legal basis standpoint, the activities described in the Enforcement Release are clear violations as (i) dealings in (including an unlicensed “transfer” of) “blocked property,” i.e. the real estate located within the U.S. in which the blocked person had an interest, (ii) the provision of services to the blocked owners of the properties, and (iii) the receipt of funds from the blocked owners of the properties. OFAC refers to “U.S. Person-1’s resolution of criminal charges with the Department of Justice related to a subset of the apparent violations” (see https://storage.courtlistener.com/recap/gov.uscourts.flsd.679897/gov.uscourts.flsd.679897.1.0.pdf for further information).

2) The enforcement action makes clear that property “jointly” owned by...