OFAC License for Inheritance: When an Heir Needs One
The three configurations that turn an estate into a sanctions matter
An OFAC license for inheritance is needed far less often than clients fear. There is no general embargo on dealings with Russia by US persons, and most cross-border estates close without a single filing in Washington. The procedural side of those files, like deadlines, powers of attorney, currency control, and bank...
Can You Speed Up an OFAC Delisting Decision?
No Fixed Deadline for an OFAC Delisting Decision
A delisting petition is filed under 31 C.F.R. § 501.807. The petitioner must show either that there was no sufficient basis for the designation in the first place, or that the circumstances giving rise to it no longer exist. A petitioner can also propose specific remedial measures to address the reasons for the listing, such as a change in...
Refiling a Delisting Petition: How to Use Prior Denials
How Many Times You Can File a Delisting Petition
There is no formal cap on the number of delisting petitions a party may file with OFAC; neither 31 C.F.R. § 501.807, nor any other OFAC regulation limits the number of attempts. Refiling a delisting petition is, in that narrow sense, always available. In practice, however, this does not mean refiling is worthwhile on its own terms: the number...
Russians Denied US Bank Accounts: Why Banks Refuse Service Even Without Sanctions
A phenomenon broader than sanctions
Many Russian citizens assume that if they are not named on the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List, hold no blocked assets, and face no individual restrictions, a US bank has no real basis to turn them away. In practice, Russians denied US bank accounts is a routine outcome, and it happens regardless of whether...
OFAC GL 131H: Eighth Extension in a Row Gives Lukoil International GmbH Deal Until August 22
On July 24, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License No. 131H (OFAC GL 131H), replacing General License No. 131G and extending the authorization for negotiations and contingent contracts for the sale of Lukoil International GmbH (LIG) until August 22, 2026. LIG is the Austrian holding company through which PJSC Lukoil manages...
Asset Unblocking After Delisting: Why There’s No Automatic Return
What Delisting Actually Changes, Legally
When the Office of Foreign Assets Control (OFAC) removes a person or entity from the SDN List, one specific thing happens: the entry is deleted from the sanctions list. As a legal matter, the individual or company is no longer a blocked person under U.S. sanctions law. But a delisting decision is not, by itself, an instruction to any bank to release a...
OFAC SDN Delisting: Lawsuit or Petition? Lessons from the Zadornov, Buriko, and Maltsev Cases
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...
Indian Companies Delisting: OFAC Removes Four Firms from the SDN List
What Happened on June 30, 2026
On June 30, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed four Indian companies from the Specially Designated Nationals and Blocked Persons List (SDN List) under the RUSSIA-EO14024 program. This Indian companies delisting covered RRG Engineering Technologies Private Limited and Lokesh Machines Limited (both based in...
New OFAC Reconsideration Portal: What Has Actually Changed
What OFAC Launched on June 29, 2026
On June 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) launched a new online tool for submitting requests to be removed from its sanctions lists: the OFAC Reconsideration Portal. The portal replaces the previous practice under which petitioners submitted delisting petitions by email and then went through repeated...
OFAC Removes Turkish Sanctions Evasion Network from Russia-Related SDN List
What Happened on June 29, 2026
On June 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed seven entries from the Specially Designated Nationals and Blocked Persons List (SDN List) under the RUSSIA-EO14024 program. All seven are Turkish companies and individuals previously designated for supporting Russia's military-industrial base through sanctions...