Family International Realty LLC OFAC Settlement: $1.1M

Abramov and Perevalov were designated to the SDN List on January 26, 2018, pursuant to Executive Order 13685, for having acted for or on behalf of VAD, AO, a Russian construction company they co-founded that was hired to build transportation infrastructure for the so-called "Republic of Crimea." Prior to the designations, U.S. Person-1 had maintained longstanding financial ties to both men, including providing property management services for their South Florida condominiums, exercising power of attorney over Perevalov's bank account, and acting as the "care of" party for bank accounts jointly owned by Abramov and his spouse.

Hours after Abramov was designated, U.S. Person-1 warned Abramov via text message that "it will soon be forbidden to deal with you" while continuing to contact potential buyers. U.S. Person-1 and Abramov then arranged to deed Abramov's condominium, valued at over $1 million, to Abramov's spouse for $100 in consideration in June 2018. As U.S. Person-1 relayed to an interlocutor at the time: "Abramov understands that without this [plan], all his money and apartment will be taken away from him!" U.S. Person-1 subsequently facilitated the sale of the property to third parties in March 2019 for $1.2 million, with the Company earning a commission and reimbursement for expenses.

For Perevalov's two South Florida condominium units, U.S. Person-1 worked with a law firm to incorporate a Delaware shell company owned by one of Perevalov's non-sanctioned minor children and managed in part by U.S. Person-1. Perevalov and his spouse transferred nominal ownership of the two units to the shell company without consideration in June 2018. The Company and U.S. Person-1 then rented or attempted to rent the properties as luxury hotel rooms on 64 occasions between March 21, 2018, and March 29, 2023, generating or attempting to generate approximately $840,254 in rental revenue for the shell company, with the Company earning a commission on each completed transaction. The conduct resulted in 73 apparent violations of §§ 2(a), 5(a), and 6(a) of Executive Order 13685.

The statutory maximum civil monetary penalty applicable in this matter is $30,080,709. OFAC determined that the Company and U.S. Person-1 did not voluntarily self-disclose the apparent violations and that the apparent violations constitute an egregious case. Accordingly, under OFAC's Economic Sanctions Enforcement Guidelines, 31 CFR part 501, app. A, the base civil monetary penalty equals the statutory maximum of $30,080,709.

The Company and U.S. Person-1's obligation to pay $182,442 of the settlement amount shall be deemed satisfied up to an equal amount by their payment to the Department of Justice in satisfaction of any criminal forfeiture order imposed in connection with the conduct at issue. The total settlement amount of $1,076,923 reflects OFAC's consideration of the General Factors under the Enforcement Guidelines.

U.S. Person-1 resolved criminal charges with the Department of Justice related to a subset of the apparent violations as part of a comprehensive resolution alongside the OFAC settlement. U.S. Person-1 pleaded guilty to a criminal charge relating to the same underlying conduct, carrying a statutory maximum sentence of five years in prison and a criminal forfeiture figure of $182,442. The Company and U.S. Person-1's obligation to pay $182,442 of the OFAC settlement amount shall be deemed satisfied up to an equal amount by their payment to the Department of Justice in satisfaction of any criminal forfeiture order imposed in connection with the conduct at issue.

This case highlights the role that gatekeepers, including realtors, investment advisers, attorneys, and trust and corporate services providers, can play in enabling sanctions evasion. These professionals possess unique expertise and technical know-how that enables them to provide critical business services, but those services can also be misused to conceal a sanctioned party's interest or evade sanctions compliance controls. In doing so, gatekeepers not only risk violating sanctions themselves, but also expose others to liability. Financial institutions that deal with gatekeepers should conduct sufficient due diligence to ensure that gatekeepers are not acting as proxies for sanctioned parties, and should apply heightened scrutiny when a gatekeeper may represent or purport to represent a close family member, agent, or associate of a sanctioned person.

This action also underscores the sanctions risks associated with commercial or residential real estate transactions. FinCEN and the multilateral Russian Elites, Proxies, and Oligarchs (REPO) Task Force have published alerts including specific red flags associated with sanctions evasion, several of which were present in this case. FinCEN announced in August 2024 a final rule designed to combat and deter money laundering by increasing transparency in the U.S. residential real estate sector, effective December 1, 2025.

Lastly, this case demonstrates that the property interests of blocked persons are generally not extinguished by sham transfers of title or surreptitious efforts to obscure their connection. The broad definition of "property interest" under OFAC's regulations may result in the blocking of a wide range of SDN-controlled property. OFAC's regulations generally provide that sham transfers of title and similar attempts are null and void and without legal effect. Parties who attempt to evade OFAC sanctions through post-designation arrangements, including by substituting family members or third parties as the owners of property in which blocked persons retain an interest, may find their efforts futile.

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