Family International and Owner Pay $1.07 Million to Settle Violations of Russia Sanctions Program
Between 2018 and 2023, and 2023, Family International and Sinyavsky transferred nominal ownership of three luxury condominiums owned by two sanctioned Russian oligarchs, Valeri Abramov and Viktor Perevalov, to their non-sanctioned family members and to shell companies owned by those family members. Miami International earned $182,442 in commission fees and reimbursements through rentals of two of the properties to third parties on behalf of Perevalov and the sale of the third property on behalf of Abramov.
OFAC sanctioned Perevalov and Abramov for conduct involving a Russian-based construction company responsible for constructing the Tavrida Highway in the Russian-occupied Crimea Region of Ukraine. Perevalov was designated again by OFAC in December 2024 for operating in the construction sector of the Russian economy.
Roman Sinyavsky maintained longstanding financial ties to both Abramov and Perevalov. He provided property management services for Abramov’s and Perevalov’s respective South Florida condominiums; exercising power of attorney over Perevalov’s bank account; and acting as the “care of” party for at least three bank accounts that were jointly owned by Abramov and Abramov’s spouse. Prior to, and at the time of the OFAC designations, Roman Sinyavsky had been renting out as luxury hotel rooms two condominium units jointly owned by Perevalov and his spouse and was attempting to broker the sale of another condominium unit jointly owned by Abramov and his spouse.
Valeri Abramov
Shortly after learning of OFAC’s designations of Abramov and Perevalov, Roman Sinyavsky initiated a scheme on their behalf to transfer nominal ownership of their properties into the names of their non-sanctioned family members. Roman Sinyavsky understood that OFAC’s designations meant that transactions involving Abramov’s and Perevalov’s properties were prohibited, and therefore sought to conceal their ownership interests. Roman Sinyavsky’s conduct was designed to remove the two designated oligarchs’ names from their property titles to obscure their ownership interests and facilitate the rental and potential future sale of the properties.
OFAC cited Roman Sinyavsky’s text messages to confirm his knowledge of Abramov’s designation and the nature of the restrictions. Just hours after Abramov was designated, Roman Sinyavsky warned Abramov via text message that “it will soon be forbidden to deal with you…I talked with people who know [about this issue] here.” Nevertheless, Sinyavsky continued contacting potential buyers in an attempt to prevent OFAC’s sanctions designation from impeding a future sale.
To escape detection, Roman Sinyavsky and Abramov sought to transfer ownership of Abramov’s condominium from joint marital property to Abramov’s spouse alone, with the intent of concealing Abramov’s continued property interest. Roman Sinyavsky worked together with a law firm to deed the property, valued at over $1 million, to Abramov’s spouse for $100.
Roman Sinyavsky attempted to sell Abramov’s condominium unit in late June 2018 for $1.1 million, but the sale ultimately did not come to fruition. Following a new cash offer for the unit by third parties in January 2019, Roman Sinyavsky hired a new attorney to complete the sale. Sinyavsky and the attorney facilitated the sale of Abramov’s property to the third parties in March 2019 for $1.2 million. The Company earned a commission on the transaction and reimbursement for expenses previously incurred by Sinyavsky to maintain the property.
Viktor Perevalov
Shortly after Perevalov’s designation, Roman Sinyavsky called Perevalov to inform him of his sanctioned status. Soon thereafter, Roman Sinyavsky agreed to act on Perevalov’s instructions to conceal Perevalov’s ownership interest in his two South Florida condominium units by removing Perevalov’s name from the property title in order to continue to generate revenue from them and potentially facilitate their future sale.
In furtherance of this scheme, Roman Sinyavsky worked with the first law firm to incorporate a Delaware shell company and transfer nominal ownership of Perevalov’s condominium units. The shell company was owned by one of Perevalov’s non-sanctioned minor children and was managed in part by Roman Sinyavsky and his spouse transferred nominal ownership of their properties without consideration to the shell company in June 2018.
Following this transfer—and with Perevalov’s interest now concealed—Florida International and Roman Sinyavsky continued to rent out the properties as luxury hotel rooms until 2023. From March 21, 2018, to March 29, 2023, Florida International and Roman Sinyavsky rented or attempted to rent the properties on 64 occasions, generating or attempting to generate approximately $840,254 in rental payment revenue for the shell company.
Gatekeeper Role
OFAC emphasized the importance of of the role played by gatekeepers – including realtors, investment advisers, attorneys, and trust and corporate services providers—in enabling sanctions evasion. Such professionals possess unique expertise and technical know-how that enables them to provide critical business services. However, as demonstrated in this case and other recent actions, OFAC noted that “these services can also be misused to conceal a sanctioned party’s interest or evade sanctions compliance controls.”
OFAC also noted that the fact that significant sanctions risks are associated with commercial or residential real estate transactions. In recent years, the Department of the Treasury has highlighted these potential risks in an effort to arm individuals with the knowledge needed to identify sanctions evasion and to avoid dealing in blocked property. In particular, the Financial Crimes Enforcement Network (FinCEN) and the multilateral Russian Elites, Proxies, and Oligarchs (REPO) Task Force have published numerous alerts including specific red flags associated with sanctions evasion.
