Enforcement Release: An Unnamed Individual (22)

Date issued: Dec. 09 2025

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TURBOFAC Commentary (802 words)

Notes:

1) This is one of several “gatekeeper”-oriented enforcement actions related to the provision of services to or related to Russian oligarchs. Compare Enforcement Release: IPI Partners, LLC (private equity firm), and Enforcement Release: Family International Realty LLC (real estate company).

2) This case is remarkable as the first civil penalty assessed to an individual identified by OFAC as an attorney. It is also the largest fine imposed on any individual pursuant to a settlement agreement (where it is assumed that payment was made). Another enforcement action close in time to this one involved the imposition of fine of over $4m, but that was the statutory maximum in a context where it is less likely that the individual fined would be able to pay (Enforcement Release - An Unnamed Individual (21)).
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