September 04, 2026
In search of official confirmation for yesterday’s news about the U.S. Treasury’s authorization for the Teghut deal on June 1, we went straight to the source — the OFAC website. What we found was the only public enforcement action from that date: a $1,050,000 settlement with FTI Consulting, Inc. — a global consulting giant with more than 8,100 employees and $3.8 billion in annual revenue.
For dealings with VTB Bank!
The FTI Case Brief
Between April 2019 and May 2021, FTI Consulting provided expert economic consulting services to VTB through a Singaporean law firm intermediary. Invoices went unpaid for 90, 99, and even 198 days, which OFAC classified as prohibited “new debt” . OFAC’s message was clear: you cannot do indirectly what you cannot do directly .
FTI agreed to pay $1.05 million to settle the case.
Now, the Punchline
On the very same day — June 1, 2026 — OFAC publicised the FTI penalty. And on that same date, Dynamic Frontier Holdings stated it had received authorization from the U.S. Department of the Treasury to acquire 100% of Teghout CJSC’s shares and its outstanding debt .
One American company was fined for indirectly dealing with VTB. On the same day, another American company says it received Treasury authorization to acquire a VTB-linked asset worth hundreds of millions of dollars. The first decision is public. The second is not.
We searched the Treasury and OFAC records for June 1. What we found was the $1.05 million FTI Consulting settlement. What we did not find in the public OFAC records was the Treasury authorization that Dynamic Frontier says it received that day.
The authorization may exist as a private license, which OFAC does not publish. But until it appears, the contrast is striking.
Read the full FTI breakdown: FTI Consulting’s $1.05 Million OFAC Settlement (Volkov Law).
Bottom line:
One company was penalized for indirect VTB dealings; another says it was authorized to acquire a VTB-linked asset. On the same day. Make it make sense.