OFAC Penalty for Sanctions Violations: What Actually Reduces the Amount
The Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) does not have to prove intent. Liability attaches to the act itself: the payment cleared, the goods shipped, the account was serviced. Intent affects how much a company pays, not whether it is liable at all.
Violations also rarely look like deliberate evasion. More often they come from an ownership stake...
Person Located in Russia: How OFAC Decides This Status After a Move
Two different questions: who you are and where you are
A businessman moved to Dubai in 2022, obtained a UAE residence visa, rented an apartment, and brought his family over. The Russian passport stayed, the Moscow apartment stayed, the account at a Russian bank stayed, and his engagement letter with a US consultant still carries a Moscow address. He appears on no sanctions list. The Specially...
A US Company for Russian Citizens: What OFAC Checks and What the Bank Checks
Where the confusion usually starts
A client walks in with a Russian passport and asks whether he can own a Delaware limited liability company (LLC). Most advisers instinctively reach for the Specially Designated Nationals and Blocked Persons List (SDN List), run the name, find nothing, and say yes. That answer is right about a quarter of the time.
No US sanctions program prohibits a...
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...
OFAC Investigation: The Three Documents That Decide the Penalty
How an OFAC investigation actually begins
An OFAC investigation rarely opens with anything dramatic. It opens with an administrative subpoena from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), signed by an enforcement officer. The tone is measured. The language is broad: produce information and records concerning transactions of a certain type over a certain...
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...
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...
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...
Constitutional Claims Against OFAC: Due Process, the First Amendment, and Ultra Vires
When a client challenges sanctions in a U.S. court, the workhorse is usually the Administrative Procedure Act (APA): the court asks whether the decision of the Office of Foreign Assets Control (OFAC) was arbitrary, unexplained, or procedurally defective. That tool has a ceiling. In matters touching national security and foreign affairs, courts give OFAC substantial deference, and an “arbitrary...