OFAC's Latest Enforcement Action is a Reminder That Sanctions Lifted Does Not Mean Liability Erased

This week, OFAC announced a $3.77 million settlement with a U.S. individual for 20 apparent violations of the Syria sanctions regulations — conduct that occurred between 2018 and 2021, years before Syria sanctions were lifted in July 2025. The individual's role? Serving as an officer and board member of four Syrian real estate companies, signing financial statements, approving expenses, and supervising fee collection — all for projects under the Assad regime.

Three takeaways worth flagging for compliance teams:

1. Individual liability is real. This wasn't a corporate fine spread across a P&L. A natural person is paying $3.77 million out of pocket for conduct undertaken in a board and officer capacity. If you serve on the board or leadership team of any entity with international operations, your personal sanctions exposure follows your role — not just your employer's.

2. Lifting of the sanctions is not a defense. OFAC has made clear it will continue to enforce past violations of the Syria sanctions for conduct pre-dating the July 2025 revocation. 

3. No voluntary self-disclosure can mean egregious treatment. OFAC's Enforcement Guidelines give significant weight to VSD. In this case, the absence of a VSD was a key driver of the egregious determination — directly affecting the base penalty calculation. The cooperation message from OFAC is explicit in the settlement release.

With Syrian sanctions now lifted and a wave of new business interest in the country, this action is a timely signal: OFAC's long memory of pre-revocation conduct should be factored into any legacy sanctions risk assessment for Syria-connected transactions.