In the United States, the Treasury Department has underscored its willingness to target not only sanctioned persons but also the intermediaries who enable them. Over the past fortnight, OFAC announced two noteworthy enforcement matters.

One involved a substantial multimillion-dollar penalty imposed on an individual who had engaged in property transactions involving a blocked Russian person, including renovating and attempting to sell residential properties without securing OFAC authorization.

The second concerned a New York property-management firm that continued to administer high-value U.S. real estate for a company owned by a well-known Russian oligarch. Despite direct warnings from OFAC, the firm allegedly continued routine property-management payments, prompting a penalty of more than seven million dollars.

These paired cases show a clear trend: the U.S. government increasingly views real-estate managers, brokers, advisors, and other “gatekeepers” as central actors in sanctions enforcement. Even routine administrative services – maintenance payments or minor operating expenses – can constitute prohibited dealings when they benefit a blocked person.