FTI Consulting (FTI), a Washington, D.C.-based international consulting and advisory firm, has reached a settlement with the Office of Foreign Assets Control (OFAC) over alleged violations of sanctions targeting VTB Bank OAO (VTB), a Russian state-owned bank. Even though it had contracted with an unnamed law firm – not directly with VTB – for legal support work, FTI still wound up in hot water with OFAC, underscoring the principle that a company cannot do indirectly what is prohibited directly. This article discusses the settlement and its compliance implications, with insights from experts at Berliner Corcoran & Rowe, Lowenstein Sandler and Buchanan Ingersoll & Rooney. See our three-part sanctions 101 series: “How Sanctions Regimes Work” (Aug. 3, 2022), “Their Impact on Private Fund Investors and Investments” (Aug. 17, 2022) and “How to Comply With Them” (Sep. 14, 2022).