OFAC settles with FTI Consulting for $1.05 million over indirect VTB debt dealings

WASHINGTON, June 1, 2026 — The U.S. Department of the Treasury’s Office of Foreign Assets Control announced a $1.05 million settlement with FTI Consulting Inc. over apparent violations of Russia-related sectoral sanctions, saying the Washington-based advisory firm indirectly dealt in prohibited debt of VTB Bank on six occasions between April 2019 and May 2021.

OFAC said FTI, working through a law firm on litigation for VTB in Singapore, issued invoices that were ultimately to be paid by VTB, a Russian state-owned bank on OFAC’s Sectoral Sanctions Identification List and subject to Directive 1 restrictions on new debt of longer than 14 days maturity. According to the enforcement release, invoices went unpaid or were paid well beyond the permissible tenor while FTI continued to perform services, which OFAC said amounted to indirect dealings in prohibited debt.

The agency said the case was non-egregious and not voluntarily self-disclosed, although FTI later notified OFAC after investigating the conduct and cooperated with the probe. OFAC said the $1.05 million settlement was above the $525,000 base penalty schedule amount, reflecting its view that the case should help promote compliance by similarly situated firms.

OFAC highlighted several aggravating factors, including that FTI and certain senior managers recognized sanctions risks at the outset but still missed repeated warning signs, continued work despite overdue invoices, and participated in discussions with VTB about late payments. The agency also said the payment structure obscured activity that might otherwise have been screened more effectively by intermediaries.

As mitigation, OFAC cited FTI’s cooperation, the relatively small transaction volume compared with the firm’s overall business, and compliance enhancements including added sectoral sanctions training, revised screening policies and stronger controls adopted after Russia’s full-scale invasion of Ukraine. The action underscores OFAC’s warning that U.S. persons cannot do indirectly what they are barred from doing directly.