Treasury Crackdown Sparks $4.7M Penalty as New Data Reveal Massive U.S. Foreign Holdings

US Department of the Treasury

WASHINGTON, D.C. — The U.S. Department of the Treasury issued two major announcements this past week, unveiling a sweeping $4.7 million sanctions penalty tied to a concealed real-estate deal involving a blocked Russian individual, while also releasing new data showing U.S. investors held nearly $15.8 trillion in foreign securities at the close of 2024.

In the sanctions case, the Treasury’s Office of Foreign Assets Control (OFAC) imposed the statutory maximum penalty of $4,677,552 against an unnamed U.S. investor—identified only as “U.S. Person-1”—for willfully violating Russia-related sanctions and ignoring a federal subpoena. According to OFAC, the individual secretly mortgaged, renovated, and sold an Atlanta-area property owned by a sanctioned family member of a Russian oligarch despite explicit federal warnings that the property remained legally blocked.

Treasury officials said the case demonstrates the Biden-era backlogs President Trump sought to eliminate and signals an intensified enforcement posture toward individuals attempting to bypass sanctions through real estate or corporate structures.

“Treasury will continue to actively investigate and hold accountable those who violate U.S. sanctions,” said John K. Hurley, Under Secretary for Terrorism and Financial Intelligence. “Today’s action shows our commitment to enforcing the law and disrupting attempts to conceal dealings with blocked persons.”

A Hidden Foreclosure and a Concealed Sale

The blocked Atlanta property became subject to full U.S. sanctions in March 2022 under Executive Order 14024, which targets Russian individuals engaged in malign foreign activities. Local officials, at OFAC’s request, publicly recorded the sanctions restrictions in Fulton County property records—yet the home proceeded into foreclosure and was purchased at auction by King Holdings LLC, the real-estate company run by U.S. Person-1.

OFAC discovered the foreclosure in April 2023 and informed the investor that the property was still legally blocked and that any transfer or sale required an OFAC license. Instead of seeking authorization, investigators say the investor continued renovations, marketed the home, and quietly advanced toward a sale in violation of a federal cease-and-desist order.

When served with a subpoena demanding full disclosure, U.S. Person-1 certified their response as complete—omitting the impending sale—and closed on the property soon after, triggering the maximum allowable civil penalty.

Treasury Announces Contingency CPI for TIPS

In a separate announcement, Treasury activated its contingency procedures for Treasury Inflation-Protected Securities (TIPS) due to a lapse in federal appropriations that prevented the Bureau of Labor Statistics from releasing October 2025 Consumer Price Index (CPI) data.

Under federal rules, Treasury must calculate an index number when CPI is unavailable. It determined the October 2025 index value to be 325.604, based on formulas in the Uniform Offering Circular. This number will remain binding even if BLS later publishes actual CPI figures.

New Treasury Survey Shows $15.8 Trillion in U.S. Foreign Holdings

Treasury also released the latest findings from its annual survey of U.S. portfolio holdings of foreign securities, conducted jointly with the Federal Reserve. The data reveal American investors held $15.8 trillion in foreign securities at year-end 2024, up from $15.3 trillion in 2023.

According to the report:

  • $12.1 trillion was in foreign equities
  • $3.3 trillion was in long-term foreign debt
  • $0.4 trillion was in short-term foreign debt

The Cayman Islands remained the largest destination for U.S. portfolio investment at $2.8 trillion, followed by the United Kingdom at $1.6 trillion, Canada at $1.5 trillion, and Japan at $1.2 trillion. Together, these four jurisdictions accounted for 45% of all U.S. foreign securities holdings, according to detailed tables included in the survey.

Broader Context: Foreign Holdings and Enforcement Priorities

The portfolio-investment data form part of the IMF’s global Coordinated Portfolio Investment Survey and represent a key measure of U.S. cross-border exposure. Treasury is simultaneously preparing an updated survey of foreign holdings of U.S. securities, with preliminary results expected in February 2026.

Taken together, the sanctions penalty, contingency index announcement, and foreign-investment report show a department operating on multiple fronts—focusing on sanctions enforcement, market stability, and transparency in global capital flows.

Treasury signaled it will continue publicizing high-profile enforcement actions to deter sanctions evasion, particularly in real estate, where officials warn that blocked property transactions are increasingly being used to obscure links to sanctioned actors.

More information, including full tables and historical comparisons, is available in the Treasury document Report on U.S. Portfolio Holdings of Foreign Securities at Year-End 2024.

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