What Happened on June 11, 2026

On June 11, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) updated its Specially Designated Nationals and Blocked Persons List (SDN List). Two Russia-linked individuals were removed: Sergey Aleksandrovich Maltsev, a former deputy chairman of the management board of Sberbank, and Olga Borisovna Raykes, a businesswoman holding Russian and Israeli citizenship.

Maltsev was added to the SDN List on May 8, 2022, as part of sanctions targeting Sberbank’s senior leadership under Executive Order 14024 (EO 14024). Shortly afterward, he left the bank together with board members Aleksandra Buriko and Natalia Alymova, a departure the bank announced on May 17, 2022. Raykes was designated later, on February 24, 2023, as a co-founder and principal of the multi-family office Confideri; OFAC tied her to activity in the financial services sector of the Russian economy.

OFAC did not publicly explain why it granted relief. Even so, this OFAC SDN delisting fits a broader and increasingly visible pattern that took shape over 2026.

The 2026 Wave of Delistings

The June 11 action was anything but isolated. Over a matter of months, OFAC removed a series of prominent figures previously connected to the Russian state and financial institutions.

In December 2025, OFAC delisted Aleksandra Buriko, a former chief financial officer and board member of Sberbank. March 2026 brought the removal of Evgenia Tyurikova, who had led Sberbank’s Private Banking division. In late March 2026, OFAC lifted sanctions on Vladimir Dmitriev, the former head of the state development corporation VEB.RF, who had been designated since May 2022. In early April 2026, the list shed Mikhail Zadornov, a former Russian finance minister and ex-chairman of the bank FC Otkritie.

Against that backdrop, the removal of Maltsev and Raykes looks like a natural continuation. These cases share a common thread: where a designation rested on a specific role or position, the person eventually severed ties with that basis, and the circumstances that prompted the block ceased to apply.

Two Routes Off the SDN List: Petition and Lawsuit

Anyone pursuing an OFAC SDN delisting has two principal legal routes, and they are not mutually exclusive.

The first is administrative. The interested party files a request for reconsideration with OFAC under 31 C.F.R. § 501.807, showing either that an insufficient basis exists for the listing or that the circumstances behind it no longer apply. OFAC reviews the request, may ask for additional documents, and ultimately decides.

The second route is judicial. If the agency delays or denies relief, the petitioner may go to federal court, most often the U.S. District Court for the District of Columbia (D.D.C.), under the Administrative Procedure Act (APA) or other applicable norms of the federal law. The court examines whether OFAC acted arbitrarily, capriciously, or contrary to law.

In practice, the two paths often work together: filing suit frequently becomes the lever that moves a stalled administrative review forward. A well-built OFAC SDN delisting strategy, therefore, keeps both routes in play at once.

The Zadornov and Buriko Cases

The Zadornov and Buriko cases show how the judicial route can accelerate the outcome.

Mikhail Zadornov filed suit in the D.D.C. in July 2024 and was delisted in early April 2026. Aleksandra Buriko went to court in December 2024, challenging the continued sanctions after she had left Sberbank soon after the bank entered the sanctions regime; she was removed in December 2025. In both cases, going to court either triggered administrative reconsideration or markedly sped it up.

The practical lesson, one we have noted before, is that the D.D.C. is not merely one possible forum among many but the most predictable tool for those challenging OFAC decisions. A deep body of case law and procedural clarity make it especially valuable.

The Maltsev Case: Delisting Without a Lawsuit

The Maltsev case is interesting because it appears to have followed a different script.

Unlike Zadornov and Buriko, there is no public record that Maltsev or Raykes ever sued the Treasury Department. That suggests their relief came through the administrative channel (a request for reconsideration) without litigation.

The facts of the Maltsev case nearly mirror Buriko’s: both sat on Sberbank’s management board, and both left the bank in May 2022, soon after sanctions landed. Buriko prevailed through the court; Maltsev, by all appearances, through the administrative path. This is a clear illustration that, where the separation from the listing basis is clean, either route can reach the goal, and that an OFAC SDN delisting need not always run through a courtroom.

The Raykes Case: Why the Company Stayed Blocked

The Raykes case adds an important caution that is easy to miss.

OFAC removed Olga Raykes herself, as an individual, but the Austrian company she co-owns, Vend Ore GmbH, was not taken off the list. On the same day, OFAC merely updated that firm’s entry. What is more, Confideri’s other co-founder, Marat Savelov, remains under sanctions.

The takeaway is simple and important: an OFAC SDN delisting of an individual does not, by itself, free the companies and partners tied to that person. Each blocked party is a separate entry on OFAC’s list, and removing a company usually requires its own basis and its own petition. Freeing the owner does not automatically free the business.

Practical Takeaways

What practical lessons can be drawn from this run of 2026 decisions?

First, the outcome turns largely on how convincingly the petitioner shows that the basis for the listing no longer holds. Stepping down from a role, exiting a business, ending the former activity – all of this strengthens the position.

Second, the choice between a petition and a lawsuit is a question of strategy, not ideology. When OFAC handles a request within a reasonable time, the administrative path may be enough. When the agency stalls or stays silent, going to the D.D.C. becomes an effective lever.

Third, relief must be sought individually for each person and each company: removing one party does not extend automatically to the structures around it.

The attorneys at Fesenko, P.C. Law Offices help prepare requests for reconsideration, build the evidentiary record, and, where needed, carry a case through federal court. If you or your company are under sanctions, a well-built strategy can turn an OFAC SDN delisting from an abstract possibility into a reachable goal.