The sanctions regime administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) can pose significant risks for PE firms, including when sanctions are imposed on an existing investor. In 2018, a PE firm secured a $50‑million capital commitment from an entity affiliated with a Russian billionaire, whom OFAC subsequently placed on its Specially Designated Nationals and Blocked Persons list. After conducting due diligence and seeking the advice of counsel, the firm determined that the sanctioned individual did not have an interest in the investor entity. Subsequently, OFAC alleged that the sanctioned individual indirectly controlled the entity, and that, as a result, the firm had dealt in that individual’s property interests in violation of U.S. sanctions. In December 2025, the firm agreed to pay nearly $11.5 million to settle the matter, according to OFAC’s enforcement release (Release). This article parses the Release, with commentary from Lowenstein Sandler counsel Abbey E. Baker and MoloLamken partner Walter H. Hawes IV. See our three-part series on sanctions: “How Sanctions Regimes Work” (Sep. 13, 2022); “Their Impact on Private Fund Investors and Investments” (Sep. 20, 2022); and “How to Comply With Them” (Sep. 27, 2022).