Nearly $4 Million OFAC Penalty for Role in Syrian Luxury Real Estate Projects
28/02/2026
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced on February 25, 2026, that a natural U.S. person ("U.S. Person-1") has agreed to pay $3,777,000 to settle their potential civil liability for 20 apparent violations of OFAC sanctions on Syria that were previously in effect.
Between January 2018 and December 2021, U.S. Person-1 provided managerial services to Syria in their capacity as an officer and board member of four Syrian real estate companies, in support of several luxury real estate projects.
These services included reviewing and signing financial statements, approving budgets and expenses, supervising operations, participating in meetings, and handling personnel and marketing decisions.
The settlement amount reflects OFAC's determination that U.S. Person-1's conduct was egregious and not voluntarily self-disclosed. The violations occurred under the former Syrian regime of Bashar al-Assad, before the lifting of U.S. sanctions on Syria in 2025.
This case highlights ongoing accountability for sanctions violations even after programs are repealed and underscores the importance of compliance for U.S. persons, regardless of residence.
For more information, see the OFAC announcements and Enforcement Release
- OFAC Announcement: https://ofac.treasury.gov/recent-actions/20260225_66
- Settlement Agreement PDF: https://ofac.treasury.gov/media/935041/download?inline=
- https://ofac.treasury.gov/recent-actions/20260225_66
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.