When sanctions are imposed on an existing business partner, firms can find themselves in a sticky situation. In a settlement with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), private equity firm IPI Partners, LLC (IPI) agreed to pay nearly $11.5 million after it failed to cut off ties with an entity affiliated with a Russian billionaire placed on OFAC’s Specially Designated Nationals and Blocked Persons list. IPI conducted only cursory due diligence when a deeper dive was warranted and sought advice from counsel without disclosing critical details. The Anti-Corruption Report spoke with experts to parse the settlement details and glean insights for companies on how to avoid OFAC liability. See “White Deer Sanctions Settlement Underscores the Importance of Post-Acquisition Cleanup” (Jul. 30, 2025).