U.S. Person-1 OFAC Settlement: $3.8M (2026)

U.S. Person-1 obtained U.S. permanent residency in the 1990s and subsequently became a naturalized citizen, residing outside the United States throughout the relevant period. Beginning in the mid-2000s, U.S. Person-1 assumed multiple executive and board roles in several Syrian-incorporated real estate entities (the "Syrian Companies"), established and operated as joint ventures between multiple UAE companies and individuals, including a UAE company where U.S. Person-1 also held senior positions. The Syrian Companies constructed and operated several large-scale luxury real estate projects in Syria — planned communities with indoor and outdoor amenities and commercial centers — with holdings historically valued at over $1.5 billion.

Between January 2018 and December 2021, U.S. Person-1 served in an active leadership role in the Syrian Companies and provided a range of managerial services in support of their operations in Syria. These services included routinely reviewing and approving operational and employee expenses; receiving, modifying, and approving budgets; signing company financial statements; participating in board and shareholder meetings; and personnel management, including the hiring, promotion, and termination of employees. U.S. Person-1 was also involved in day-to-day matters such as maintenance activities and in the Syrian Companies' marketing activities.

U.S. Person-1 knew or should have known that Syria was subject to sanctions and that their conduct was prohibited. Despite engaging in this conduct for many years, U.S. Person-1 only stopped after receiving an administrative subpoena from OFAC. These activities constituted 20 apparent violations of section 542.207 of the Syrian Sanctions Regulations (SySR).

OFAC determined that 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 C.F.R. part 501, Appendix A, the base civil monetary penalty applicable in this matter equals the applicable schedule amount, which is $7,554,000. The settlement amount of $3,777,000 reflects OFAC's consideration of the General Factors under the Enforcement Guidelines.

This case highlights that OFAC's prohibitions apply to all U.S. persons, including U.S. citizens residing outside of the United States. As in most OFAC sanctions programs, OFAC's Syria sanctions program defined a U.S. person to include any U.S. citizen or permanent resident, wherever located. Upon becoming a U.S. lawful permanent resident, and later a naturalized citizen, U.S. Person-1 became subject to the same compliance obligations as all other U.S. persons, regardless of their country of residence or operations. Even though U.S. Person-1 resided at all relevant times outside of the United States and the Apparent Violations did not otherwise involve the United States, U.S. Person-1's conduct was prohibited.

This case also underscores that OFAC will hold those who violate U.S. sanctions accountable, even if such sanctions are later lifted. It is not a defense to liability that U.S. sanctions are no longer in place, and parties should not attempt to "read the tea leaves" and get ahead of any potential changes to U.S. sanctions in a manner that violates OFAC regulations. OFAC will actively enforce against violations of the sanctions in force at the time the relevant conduct occurred.

Finally, this case illustrates the importance of cooperating with OFAC's investigations. OFAC considers the nature and extent of an investigative subject's cooperation when considering both how to resolve an investigation and the size of any potential penalty. Timely and fulsome cooperation demonstrates that an investigative subject understands the seriousness of their sanctions compliance obligations and allows OFAC to complete its investigation efficiently. Failure to cooperate in a manner that is complete and satisfactory not only risks foregoing mitigation credit for cooperation, but can also risk standalone penalties under OFAC's Reporting, Procedures and Penalties Regulations.

This page summarizes an OFAC enforcement case based on the document archived below. SanctionsLookup assumes no liability for errors, omissions, or inaccuracies in the original documents, this summary, or any changes made to the source documents at any time.

Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.