OFAC has reached a settlement with a natural U.S. person for $3,777,000, resolving 20 apparent violations of Syrian sanctions regulations. The individual provided managerial services to four Syrian real estate companies between January 2018 and December 2021, supporting luxury real estate projects. OFAC determined the conduct to be egregious and not voluntarily self-disclosed, reflecting the settlement amount.

This enforcement action highlights the strict penalties for engaging with sanctioned entities, even indirectly through managerial services. Companies and individuals involved in international business, particularly in sectors like real estate, must ensure rigorous compliance with OFAC sanctions programs. Failure to do so can result in significant financial penalties, as demonstrated by this settlement. No specific compliance deadline is mentioned, but the settlement itself implies immediate action to resolve potential liabilities.