OFAC fines FTI Consulting $1.05M for bypassing Russia sanctions by indirectly extending prohibited credit to VTB through structured payments

Between 2019 and 2021, FTI Consulting provided services that ultimately resulted in unpaid invoices being structured through a third-party law firm arrangement. Although the payments were routed indirectly, OFAC determined that the structure effectively constituted an extension of “new debt” or credit to VTB, which is prohibited under the Sectoral Sanctions Identification (SSI) restrictions. The case highlights OFAC’s view that sanctions liability depends on the economic substance of a transaction rather than its formal structure, meaning indirect or intermediary arrangements do not shield companies…