A $3.77 million penalty against one person: what to do the moment an OFAC inquiry becomes personal.
A U.S. person managed Syrian real estate ventures for years and received highly limited cooperation credit after responding slowly to OFAC.
Enforcement · 25 Feb 2026
A single U.S. person agreed to pay $3,777,000 to resolve 20 apparent violations of U.S. sanctions on Syria — no company between the individual and the penalty. They held board and executive roles at Syrian real estate joint ventures for years, and stopped only after an OFAC subpoena arrived.
What happened
Between January 2018 and December 2021 they reviewed financial statements, approved budgets, and oversaw operations of Syrian developments under sanctions in force at the time — services barred for U.S. persons under the Syrian Sanctions Regulations. Because the conduct was egregious and not voluntarily disclosed, the base penalty was the reported base penalty, $7,554,000; the settlement was exactly half.
Delay reduced cooperation credit. Their cooperation after the initial subpoena was "initially limited"; only after a Pre-Penalty Notice did they retain new counsel and engage seriously. OFAC gave highly limited credit because of that delay.
If OFAC is already looking at you
Prompt cooperation can mitigate a penalty, and delay can reduce the credit OFAC gives. The Guidelines also contemplate evidence submitted after a Pre-Penalty Notice; they do not establish a categorical early window after which cooperation cannot count. Decisions about production and tolling can affect legal rights. Declining a tolling agreement is not an aggravating factor under the Guidelines. Where OFAC examines an individual, do not assume the entity’s counsel also represents that person; joint representation requires a separate conflicts assessment.
We help companies assess exposure when an employee’s conduct abroad raises sanctions questions. Contact Zimmermann Law to talk it through.
Sources: OFAC, An Individual enforcement release (February 25, 2026), pp. 1–3; Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, appendix A, §§ III.G, V.A.2–3, V.B.2(b); N.Y. Rule of Professional Conduct 1.13(d). The Guidelines are U.S. federal enforcement standards; the professional rule is mandatory New York authority within its scope. This article describes historical Syria restrictions. Checked October 2, 2026.
This post is for general information and is not legal advice.
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