OFAC Fines FTI Consulting $1.05M for Sanction Violations Involving VTB Bank
Severity: Medium (Score: 43.0)
Sources: www.grcreport.com, Comsuregroup, Globalinvestigationsreview, Ofac.Treasury
Published: · Updated:
Keywords: consulting, ofac, over, settlement, department, treasury, office
Summary
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. Key Points: • 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.
Detailed Analysis
**Impact** FTI Consulting, a global advisory firm, was fined $1.05 million by OFAC for violating U.S. sanctions targeting Russia’s financial sector. The violations involved indirect dealings with VTB Bank, a Russian state-owned lender on OFAC’s Sectoral Sanctions Identification List, between April 2019 and May 2021. The case affects the professional services sector, particularly firms engaged in cross-border financial and legal consulting, with implications for compliance in U.S. and international jurisdictions. **Technical Details** The violation stemmed from FTI’s use of a global law firm as an intermediary to issue invoices to VTB Bank, allowing payment delays well beyond the 14-day maturity limit on new debt prohibited under Directive 1 of Executive Order 13662. This arrangement effectively extended prohibited credit to VTB on six occasions, with invoice payment delays ranging from 35 to 198 days. No malware, CVEs, or cyberattack infrastructure were involved; the issue was a sanctions compliance failure related to transaction structuring and credit risk assessment. **Recommended Response** Organizations should review and enhance sanctions compliance programs to evaluate the economic realities of transactions beyond formal contract terms, especially when intermediaries are involved. Implement monitoring for delayed payments or extended credit arrangements that may violate sanctions. Legal and compliance teams must ensure all engagements with sanctioned entities comply with U.S. Treasury directives, and conduct periodic audits of invoicing and payment processes related to high-risk jurisdictions.
Source articles (4)
- Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign ... — Ofac.Treasury · 2026-06-01
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today announced a settlement with FTI Consulting, Inc. ("FTI"). FTI agreed to remit $1,050,000 to settle its potential civ… - OFAC fines FTI Consulting $1m over VTB payments — Globalinvestigationsreview · 2026-06-02
The US sanctions agency said the enforcement action – stemming from FTI’s “unique payment arrangement” with US-sanctioned Russian lender VTB Bank – emphasises a “foundational principle” that companies… - Advisory Firms Beware: OFAC Slaps FTI Consulting $1.05M Over VTB Bank Debt Deals — Comsuregroup · 2026-06-02
On June 1, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $1,050,000 settlement with FTI Consulting, Inc. ("FTI"), a global advisory and consulting fir… - Ofac Fines Fti Consulting 1 05 Million Over Prohibited Dealings With Russian State Owned Bank Vtb — www.grcreport.com · 2026-06-02
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has reached a $1.05 million settlement with consulting giant FTI Consulting over apparent violations of U.S. sanctions tar…
Timeline
- 2019-04-01 — FTI Consulting begins work with VTB Bank: FTI Consulting starts providing economic consulting services related to litigation involving VTB Bank.
- 2021-05-31 — Last prohibited debt transaction with VTB: The last of six indirect debt transactions with VTB occurred, violating U.S. sanctions.
- 2026-06-01 — OFAC announces settlement with FTI Consulting: OFAC announces a $1.05 million settlement with FTI Consulting for sanctions violations involving VTB Bank.
- 2026-06-02 — News coverage of OFAC settlement: Multiple news outlets report on the OFAC settlement with FTI Consulting, highlighting the implications for sanctions compliance.
Related entities
- FTI Consulting (Company)
- VTB Bank (Company)
- Russia (Country)
- Singapore (Country)
- Ukraine (Country)
- comsuregroup.com (Domain)
- [email protected] (Email)
- Financial (Industry)