OFAC Fines FTI Consulting $1.05M for Sanction Violations Involving VTB Bank

• •FTI Consulting fined $1.05 million for violating U.S. sanctions against VTB Bank.
• •The violations involved indirect dealings in prohibited debt over multiple instances.
• •OFAC emphasized that sanctions apply to both direct and indirect transactions.

On June 1, 2026, OFAC announced a $1.05 million settlement with FTI Consulting for violations of U.S. sanctions against Russia. The firm was found to have indirectly extended prohibited debt to VTB Bank on six occasions between April 2019 and May 2021. This arrangement allowed VTB to delay payments beyond the 14-day maturity limit set by U.S. sanctions. OFAC determined that FTI's conduct was non-egregious and not voluntarily self-disclosed. The enforcement action emphasizes that sanctions apply equally to direct and indirect dealings. FTI's invoices to a law firm acting as an intermediary were deemed to constitute new debt under the sanctions. The settlement reflects OFAC's stance that firms must assess the economic realities of transactions rather than relying solely on formal contracts.