A real estate executive reached a $3.77 million settlement with the Office of Foreign Assets Control after OFAC accused them of violating U.S. sanctions against Syria. The person — who committed the alleged violations years before the U.S. repealed a host of Syria restrictions in 2025 — provided “managerial services” in their position as a senior official and board member of four Syrian real estate companies.

OFAC noted that the person did not voluntarily disclose the 20 alleged violations of the Syrian Sanctions Regulations, and the agency called the case “egregious.” The person only stopped violating the sanctions after receiving a subpoena from OFAC.

OFAC stated the person was a naturalized U.S. citizen but lived outside the U.S., where they held senior positions in real estate firms operating in the Middle East and North America. They also held multiple executive and board roles in several Syrian real estate entities beginning in the mid-2000s, and those entities were run as joint ventures with people and companies based in the United Arab Emirates.

The companies were worth “as high as over $1.5 billion.” In his/her various roles, the person “routinely reviewed and approved operational and employee expenses” for the companies while approving budgets and signing company financial statements. The person also participated in board and shareholder meetings and was involved in hiring, promoting and firing employees, along with other “day-to-day matters” and marketing activities.

According to OFAC, the person should have known that their conduct was “prohibited” because Syria was subject to sanctions. The agency also noted that the alleged violations occurred under the former regime of Syrian president Bashar al-Assad, which oversaw “countless human rights abuses” and drug trafficking.

OFAC cited several aggravating factors that it said led to the penalty, including the fact that the real estate executive “acted with reckless disregard” for U.S. sanctions requirements, should’ve known that their activities were prohibited, and “engaged in a multi-year pattern of violative conduct and only stopped after receiving an administrative subpoena from OFAC.”

The person is an “experienced real estate professional with experience working in executive and/or board service functions for real estate-related companies with longstanding and extensive operations in the Middle East and North America.” OFAC also pointed to some mitigating factors, including the fact that the person hadn’t received a penalty notice in the previous five years and agreed to extend the case’s statute of limitations.

In noting the person’s cooperation, OFAC only awarded some credit to the person because, after receiving the subpoena, the person’s cooperation was “initially limited.” Later in the process, the person hired a new lawyer after receiving a pre-penalty notice from the agency and “improved their cooperation.” The person’s “substantial delay in meaningfully cooperating resulted in highly limited mitigation credit for cooperation,” OFAC said.

In citing lessons learned, OFAC noted that most of its sanctions apply to any U.S. citizen or permanent resident wherever they’re located, and even if they’re living at all times outside the U.S. The agency also stressed that it will still hold sanctions violators “accountable” even if the agency later lifts the sanctions, as the U.S. has done with Syria over the last year. “It is not a defense to liability that U.S. sanctions are no longer in place, and parties should not attempt to ‘read the tea leaves’ and get ahead of any potential changes to U.S. sanctions in a manner that violates OFAC regulations.” “OFAC will actively enforce against violations of the sanctions in force at the time the relevant conduct occurred.”