The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has ramped up enforcement of economic sanctions across multiple sectors, from trade logistics to financial services and traditional exporters. The below cases, while not an exhaustive list of recent actions, underscore OFAC’s diverse enforcement focus and highlight key themes such as the importance of voluntary self-disclosure, robust sanctions compliance programs, and thorough due diligence across all transaction types.
GVA Capital Settlement
Coming in at a whopping $215,988,868, the penalty that OFAC levied against GVA Capital Ltd. (“GVA Capital”) is the third largest since 2019, trailing only the Binance and British American Tobacco settlements, which both occurred in 2023. Between 2018 and 2021, GVA Capital, a San Francisco-based venture capital fund, allegedly managed the assets of the Specially Designated National (“SDN”) Russian oligarch Suleiman Kerimov in violation of the Ukraine-/Russia-Related Sanctions Regulations. OFAC designated Mr. Kerimov as an SDN on April 6, 2018, and his property and interests in property should have been blocked, or generally “untouchable” without OFAC authorization, from that point forward. However, OFAC alleges that GVA Capital continued to manage Mr. Kerimov’s assets by working through Kerimov’s nephew, Nariman Gadzhiev.
In its June 12, 2025, press release announcing the nearly quarter billion dollar penalty, OFAC acknowledges that it imposed the statutory maximum penalty based on GVA’s failure to voluntarily self-disclose the violation and OFAC’s determination that the violations were egregious. As part of the press release, OFAC also emphasized “the importance of gatekeepers in preventing sanctions evasion and highlights the risks of facilitating such efforts.” OFAC further provided examples of “gatekeepers” as “investment professionals, accountants, attorneys, and providers of trust and corporate formation services” and cautioned these professionals to “remain vigilant of the risk that unscrupulous actors, including sanctioned parties or their proxies, may seek to use professional services to conceal a property interest or otherwise evade OFAC sanctions.”
Unicat Catalysts Settlement
On June 16, 2025, OFAC announced a settlement with Unicat Catalysts Technologies, LLC (“Unicat”), a Texas-based seller of catalysts, for $3,882,797 for violations of Iranian and Venezuelan sanctions regimes. The OFAC settlement was concurrent with settlements with the Department of Justice and the Department of Commerce Bureau of Industry and Security (“BIS”). Catalysts are substances used in pretrochemical refineries and steel mills, among other use cases, to accelerate chemical reactions. Between 2016 and 2021, Unicat employees, including the co-founder and CEO, supplied Iranian customers with catalyst products and consulting services. Additionally, Unicat sold goods to a blocked Venezuelan entity.
Specifically, OFAC found that Unicat’s former CEO engaged in willfully conducted business with Iran, including intentionally concealing sales to Iran by using its Dutch affiliate and Unicat-branded Chinese supplier. Unicat also sold to Venezuelan company Ornoco Iron S.C.S. (“Orinoco”), which was owned by the Venezuelan government and thus subject to blocking sanctions. Similar to its transactions with Iran, Unicat obscured its prohibited dealings with Orinoco by working with the Chinese company to ship directly from China to Orinoco in Venezuela. Unicat voluntarily disclosed the violations subject to the enforcement action.
Fracht FWO Settlement
Fracht FWO Inc. (“Fracht”), a Texas-based freight forwarder, agreed to pay $1,610,775 to settle apparent violations involving Venezuela and Iran sanctions related to transportation of car parts from Mexico to Argentina using blocked aircraft and entities. On September 3, 2025, OFAC announced the settlement, finding Fracht liable for contracting with a sanctioned Venezuelan government airline. Fracht’s engagement implicated the Venezuela Sanctions Regulations, the Weapons of Mass Destruction Proliferators Sanctions Regulations, the Global Terrorist Sanctions Regulations, and the Iran Transactions and Sanctions Regulations. OFAC determined the conduct was egregious and noted that Fracht did not voluntarily self-disclose the violations, both of which factors increased Fracht’s penalty exposure and reputational risk.
This case illustrates the complex risk environment facing freight forwarders and logistics providers. OFAC’s investigation revealed that Fracht contracted with Empresa de Transporte Aérecargo del Sur S.A. (“EMTRASUR”), a wholly owned subsidiary of Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos (“CONVIASA”), a Venezuelan state airline listed on the SDN list since 2020. Additionally, the chartered aircraft involved in the transaction had been blocked by OFAC for its links to Iran’s Mahan Air, which is blacklisted for proliferating weapons and supporting terrorism. OFAC found that Fracht’s violations stemmed from the company’s failure to implement sufficient controls to detect red flags involving sanctioned parties and assets. Fracht paid $885,000 to the broker (of which $825,000 went to EMTRASUR) and later a $110,000 late fee, for a total of $995,000 in charter-related payments. OFAC assessed a base penalty of $2,147,700 but settled for $1,610,775 after considering Fracht’s cooperation and remedial actions.
Interactive Brokers LLC Settlement
As announced by OFAC on July 15, 2025, Interactive Brokers LLC, a major U.S.-based electronic brokerage platform, settled for $11,832,136 for thousands of apparent sanctions violations spanning programs related to Iran, Cuba, Syria, Ukraine’s Crimea region, Russia, Venezuela, and China’s Military-Industrial Complex. Between July 15, 2016, and January 31, 2024, Interactive Brokers engaged in 12,367 apparent sanctions violations relating to its provision of brokerage and investment services to persons located in sanctioned jurisdictions. Interactive Brokers also processed trades involving securities tied to the Chinese Military-Industrial Complex, transactions with blocked persons under Russia, Global Magnitsky, Venezuela, and Syria sanctions programs, and participated in new investments in Russia.
Despite the volume and range of violations, OFAC classified Interactive Brokers’ conduct as non-egregious, and Interactive Brokers voluntary self-disclosed the violations and extensively cooperated throughout the investigation. The settlement amount reflects a significant reduction from the potential maximum penalty that could have exceeded $5 billion.
Enforcement Trends and Takeaways
The above OFAC settlements highlight divergent enforcement outcomes based on voluntary self-disclosure practices and the nature of compliance failures. Lessons to be drawn include:
- Companies that self-disclose violations and cooperate with OFAC investigations can substantially mitigate penalty exposure, even in complex matters involving thousands of transactions and multiple sanctions programs (e.g., the Interactive Brokers case). (For more information regarding voluntary self-disclosures, including submission requirements, see our recently updated VSD Handbook here.)
- Firms must maintain robust compliance systems capable of detecting and preventing transactions involving designated persons, blocked assets, or restricted jurisdictions across all business lines. (See all the above.)
- Logistics providers (e.g., Fracht), financial institutions and financial services companies (e.g., GVA Capital), and brokerage platforms (e.g., Interactive Brokers) face unique risks due to the layered nature of sanctions programs and must implement tailored monitoring and screening procedures to avoid inadvertent violations.
In summary, OFAC’s recent activities send a clear message: sanctions compliance remains a top priority, and entities subject to the expansive U.S. sanctions jurisdiction must remain vigilant to avoid violations. Proactive compliance measures coupled with prompt voluntary self-disclosures continue to be the best defenses against substantial civil penalties.
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