What Happened on June 24, 2026

On June 24, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a routine update to the Specially Designated Nationals and Blocked Persons List (SDN List), removing seven individuals, two Russian-flagged cargo vessels, and two Turkish legal entities. All were designated under the RUSSIA-EO14024 sanctions program, established by Executive Order 14024 to counter harmful activities of the Russian government.

No press release accompanied the action. Unlike the May 28, 2026 mass delisting of 76 entries, which Treasury publicly framed as part of a broader sanctions modernization initiative, the June 24 update arrived without explanation. That silence is itself informative: this is administrative maintenance, not a policy declaration. OFAC removed entries where the factual basis for designation had lapsed, without signaling any change in the overall sanctions posture toward Russia.

The individuals removed, however, are not obscure figures. Behind the technical SDN list update are senior bank executives, the former president of a U.S. industrial company in Russia, and the son of one of Russia’s wealthiest oligarchs. Examining this Russia sanctions delisting reveals how OFAC continues to evaluate designations on an ongoing basis, even as the underlying sanctions programs remain fully in force.

The Individuals: Who They Are and How They Ended Up on the List

German Valentinovich Belous, Irina Vladimirovna Kremleva, Viktor Andreevich Nikolaev, and Nadia Narimanovna Cherkasova were all senior executives at PJSC Bank Financial Corporation Otkritie (Bank Otkritie), one of Russia’s largest private banks before its 2017 government bailout and subsequent nationalization. Bank Otkritie was placed on the SDN list on February 24, 2022, and formally ceased to exist on January 1, 2025, following its acquisition by VTB Bank in December 2022 for 340 billion rubles and the completion of a full reorganization. All four individuals were listed in connection with their affiliation with the bank. With the bank itself legally dissolved, the affiliation underpinning each designation no longer exists.

Mikhail Vasilyevich Klyukin is a shareholder of PJSC Sovcombank. He holds Russian and Cypriot citizenship. Sovcombank was designated on February 24, 2022, and remains on the SDN list. Klyukin’s removal reflects a change, such as his affiliation with the designated entity.

Ivan Vladimirovich Potanin is the most prominent figure in the June 24 Russia sanctions delisting. The son of Vladimir Olegovich Potanin, president of Interros Holding and Norilsk Nickel, and one of Russia’s wealthiest individuals, Ivan was designated on December 15, 2022, alongside his father, stepmother, sister Anastasia, the yacht Nirvana, and several corporate entities. Ivan Potanin is a multiple Russian and world jet ski champion and a graduate of MGIMO.

His removal is analytically significant: Vladimir Potanin remains on the SDN list, yet his son has been delisted. This confirms that familial connection to a sanctioned person is not, by itself, an open-ended basis for maintaining a designation. OFAC requires independent grounds, and when those grounds lapse, removal follows.

Maxim Yuryevich Smirnov was formerly the President of Arconic Russia, the Russian subsidiary of U.S.-based Arconic Corporation (NYSE: ARNC), which owned the Samara Metallurgical Plant (Arconic SMZ), Russia’s largest producer of aluminum semi-finished products. He was designated on February 23, 2024, as part of the largest wave of Russia-related sanctions since the start of the war, coinciding with the second anniversary of the invasion. Samara Metallurgical Plant was designated in the same action. By that point, however, Arconic had already exited Russia: the plant had been transferred to Russian-controlled Promyshlennye Investitsii holding in 2022. Moreover, shortly before being placed on the SDN list, Smirnov resigned as president of the company. Thus, his removal from the SDN list most likely reflects precisely this circumstance: the loss of substantive affiliation with the designated entity.

Vessels and Legal Entities

Two Russian-flagged general cargo vessels were removed from the SDN list: “Vyacheslav Arshinov” (IMO 9945136) and “Gennady Egorov” (IMO 9945124). Both had been listed with a “Linked To” notation referencing the Joint Stock Company State Transportation Leasing Company (GTLK), which remains on the SDN list. Their removal likely reflects a change in registration, ownership, or operational control.

Two Turkish entities were also removed: IDA Asansor Sanayii ve Ticaret Limited Sirketi (an elevator company based in Malatya, listed under three name variations) and Dein Danismanlik Pazarlama ve Ticaret Anonim Sirketi (Istanbul). Both had been designated as intermediary entities allegedly used to circumvent existing Russia-related sanctions.

The Pattern: The Organization Stays, the Individual Goes

The June 24, 2026 Russia sanctions delisting exhibits a consistent pattern that has characterized OFAC removal decisions throughout 2026. In every case involving an individual, the sanctioned organization (the bank, the enterprise, the holding company) remains on the SDN list. What changes is the individual’s connection to it.

This has direct implications for the administrative petition process under 31 C.F.R. § 501.807. OFAC does not evaluate designation petitions by looking solely at the fact of prior affiliation with a sanctioned entity. It evaluates the current state of that affiliation, and when the connection that gave rise to the designation no longer exists, removal becomes available. A change in corporate position, departure from a board, a sale of the underlying enterprise, or changed personal circumstances can each constitute an independent basis for a successful petition.

Ivan Potanin’s removal adds a separate dimension: it establishes, through OFAC’s own conduct, that a family relationship alone does not permanently anchor a designation. Where the designated family member’s independent grounds for listing have lapsed, and no separate sanctionable conduct is alleged, removal is achievable even when a close relative remains on the SDN list.

What This Russia Sanctions Delisting Means for Those Still on the List

The June 24 action fits within a broader shift in how OFAC is managing the SDN list in 2026. The agency has signaled through both the May 28 mass removal and Secretary Bessent’s remarks at the No Money for Terror conference in Paris that sanctions should remain strategically calibrated rather than accumulating indefinitely. The June 24 Russia sanctions delisting reflects the operational side of that shift: quiet, case-by-case removal of designations that no longer carry their original evidentiary weight.

For individuals currently on the SDN list, several practical conclusions follow.

First, removal is available even when the organization that gave rise to the designation remains sanctioned. What matters is the individual’s current relationship to that entity, not its continued designation.

Second, documented changes in affiliation (resignation from a position, removal from a board, a corporate restructuring) can form the factual core of a successful petition.

Third, family ties to the remaining SDN designee are not, by themselves, an insurmountable obstacle.

OFAC does not publish uniform criteria for evaluating removal petitions under 31 C.F.R. § 501.807. Each case turns on its own facts, and the strength of the petition depends on the quality and completeness of the evidentiary record submitted. An attorney experienced in Russia sanctions delisting can assess the merits of a specific matter and structure the submission accordingly.

Fesenko, P.C. Law Offices advises individuals and entities on SDN list removal, including administrative petitions under 31 C.F.R. § 501.807 and federal court litigation against OFAC. If you or a family member is currently designated under U.S. sanctions, contact us for a confidential consultation.