OFAC Settlement with FTI Consulting, Inc.

FTI Consulting, a Washington D.C.-based global advisory firm, settled with OFAC for $1,050,000 for apparent violations of the Ukraine-/Russia-Related Sanctions Regulations (URSR) under Directive 1 of E.O. 13662. The apparent violations highlighted by OFAC in the Enforcement Release are summarised as: between April 2019 and May 2021, FTI provided expert economic consulting services in support of VTB Bank OAO, a Russian state-owned bank on OFAC's SSI list, in Singapore litigation, routing invoices through a law firm intermediary in an attempt to avoid direct dealings. Directive 1 prohibits U.S. persons from dealing in new debt of more than 14 days maturity with SSI-listed entities, and several of FTI's invoices went unpaid for 90 to 198+ days, far exceeding that limit. OFAC found the indirect structure did not shield FTI from liability. Aggravating the case, FTI's own compliance team had flagged VTB-related risks at the outset, yet the firm continued issuing invoices even as they went unpaid and even joined calls with VTB to chase payment.