What Happened on June 23, 2026

On June 23, 2026, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury published an update to its Specially Designated Nationals and Blocked Persons List (SDN List) that removed three Russian nationals: Anton Alekseevich Krugovov, Tamara Aleksandrovna Topchi, and Natalya Vladislavovna Puzyrnikova. All three had been designated under Executive Order 14024, the authority that underpins the bulk of U.S. sanctions imposed on Russia since February 2022. As of that date, U.S. persons are no longer prohibited from dealing with them, and any property previously blocked by reason of their listing is unblocked.

The June 2026 OFAC delisting is notable less for its size than for what it reveals about the criteria that can support removal. The three were not a single group: they reached the SDN List by two different routes, and separating those routes is the key to understanding the action.

Who the Three Individuals Are

Krugovov and Topchi were designated together on March 31, 2022, as part of a large action against a Russian technology-procurement network. Puzyrnikova was designated separately, on May 8, 2022, in an action targeting the boards of major Russian banks. They share an executive order and a removal date, but little else.

The Serniya Procurement Network: Krugovov and Topchi

The March 31, 2022, action centered on Moscow-based OOO Serniya Engineering, which Treasury described as the hub of a procurement network engaged in proliferation activities at the direction of Russian intelligence services. Serniya and a related company, OOO Sertal, were said to procure dual-use equipment and technology for Russia’s military-industrial complex through a web of foreign front companies, including Majory LLP in the United Kingdom and Invention Bridge SL in Spain.

Anton Krugovov was designated for being a senior executive officer of Majory LLP and for acting on behalf of Serniya and Sertal. Tamara Topchi was designated as an official of Invention Bridge SL. In both cases, the designation rested on the person’s relationship to a blocked entity rather than on independently charged conduct of their own; a distinction that matters when the basis for removal is assessed.

The Gazprombank Track: Puzyrnikova

Puzyrnikova has no connection to the Serniya network. She was designated as a member of the board of one of Russia’s largest banks, Gazprombank, for operating in the financial services sector of the Russian economy. Her designation, too, was status-based: it flowed from her position on a bank board, not from any specific transaction attributed to her personally.

Why OFAC Removed Them

Consistent with its longstanding practice, OFAC did not publish a statement of reasons for these particular removals. The June 23 notice lists the three under “Russia-related Designations Removals” without elaboration. Any explanation, therefore, has to be inferred from the structure of the original designations and the agency’s general posture.

The common thread is that all three were designated on the basis of status or affiliation. Where a person was listed because of a formal role with a designated entity, and that role has ended, or the underlying relationship no longer exists, the case for removal on the merits is comparatively strong. Public corporate records illustrate the point: Topchi now appears as the liquidator of Invention Bridge SL, winding the company down rather than operating it. Facts of that kind are precisely what an administrative removal request is built around.

It is equally important to state what this action is not. It is not a determination that the original blocking was wrong; designations and removals are distinct decisions, each made on its own record.

The June 2026 OFAC Delisting in Context

This OFAC delisting does not stand alone. Throughout 2026, OFAC has removed Russia-related parties from the SDN List at a noticeably faster pace, culminating in a May 28 batch of ten Russian citizens accompanied, unusually, by a press release describing a “sanctions modernization” effort. Treasury’s consistent message has been that SDN List removals do not signal a broader shift in U.S. policy toward Russia, and that sanctions are intended to change behavior rather than to punish.

For designated persons, the practical takeaway is that the OFAC delisting channel is active and that the agency is willing to use it. The strength of OFAC sanctions, as Treasury itself has put it, lies not only in adding names but in removing them in accordance with the law.

What This Means for Designated Persons

An OFAC delisting does not happen automatically, and it is not granted as a favor. It results from the administrative reconsideration procedure set out at 31 C.F.R. § 501.807, under which a blocked person may submit a request demonstrating that the basis for the designation is insufficient or that the relevant facts have changed. The most persuasive requests are evidence-driven: they document the end of the triggering relationship, address the specific conduct Treasury identified, and, where appropriate, propose verifiable remedial steps.

Designations that were derivative or status-based, built on a job title, a board seat, or a relationship with a blocked company, are often the most workable candidates for this kind of request once the underlying role has ended. That is the feature these three removals share, and it is a useful benchmark for anyone evaluating their own position.

How Fesenko, P.C. Law Offices Can Help

If you are considering pursuing an OFAC delisting, the threshold question is whether the original basis for your designation still holds, and what evidence can show that it does not. Fesenko, P.C. Law Offices prepares and files administrative removal requests under 31 C.F.R. § 501.807 and, where the administrative route is exhausted or inadequate, pursues relief in federal court. We work in English and Russian and represent designated individuals and companies internationally. To assess whether your situation supports a removal request, contact our office for a confidential consultation.