Small in money and unusually clean in mechanism. If you want one case that shows what threshold and nominee structuring look like when written down by a regulator, this is it.
The conduct
OFAC designated Valeri Abramov and Viktor Perevalov on 26 January 2018. Between 2018 and 2023, according to the enforcement release, the owner of Miami-based Family International Realty LLC and the company “engaged in a willful scheme to evade OFAC sanctions by transferring nominal ownership of three luxury condominiums owned by two sanctioned Russian oligarchs, Valeri Abramov and Viktor Perevalov, to their non-sanctioned family members and to shell companies owned by those family members.”
The company earned approximately $182,442 in commissions and reimbursements from renting two of the properties to third parties on Perevalov’s behalf and selling the third on Abramov’s behalf. There were 73 apparent violations.
Every element of the technique, in one paragraph
Read that description against the indicators on the threshold structuring page and they line up exactly.
Timing. The transfers follow the designation. The designation date is public and the transfer dates are on the deeds, which is why chronology is the most productive check in this area.
Transferee. Family members, which is the single most documented pattern in ownership transfers after a designation, and the reason “close family member or long-standing business associate” appears as an indicator in its own right.
Nominal ownership. OFAC’s phrase, not a paraphrase. Title moved; benefit did not.
Shell companies owned by those family members. A second layer on top of the first, so the register shows an entity rather than a person, and the person it shows behind the entity is not designated.
Continuing benefit. The properties were rented and sold on behalf of the designated persons. That is the fact that makes the transfers nominal rather than real, and it was established by what the agent did afterwards — collecting rent, remitting proceeds, taking commission.
The role of the professional
The realtor is not incidental here. Someone had to list the properties, find tenants, handle the sale and move the money, and that someone was a US person subject to the prohibition directly.
OFAC found the conduct egregious and willful, and the settlement reflects the owner’s separate resolution of criminal charges with the Department of Justice for a subset of the same conduct. A commission of $182,442 produced a penalty roughly six times that and a criminal case.
Who “the owner” is
OFAC’s notice never names him, referring throughout only to “U.S. Person-1.” A Southern District of Florida criminal docket that names Family International Realty, Abramov and Perevalov, and that closed with a guilty plea on 16 January 2025 — the same date as this settlement — identifies him as Roman Sinyavsky. Connecting an anonymised civil settlement to the public criminal record it was coordinated with is itself a small illustration of the reconciliation this site’s own detection sections describe: neither document alone gives the full picture, and the two were filed on the same day for a reason.