Buying US Real Estate as a Russian Citizen: Closing Checks, Financing and FIRPTA
No federal law stops a Russian citizen from buying a house or an apartment in the United States. A few states restrict such purchases, and those statutes turn on domicile more than on the passport.
Everywhere else, buying US real estate as a Russian citizen comes down to four practical questions: who screens the buyer on the way to closing, whether the money can be traced, whether anyone...
Usmanov and Fridman: EU Sanctions Delisting Leaves the SDN List Untouched
On 22 September 2026, hours before its own deadline, the ambassadors of the EU member states finally reached an agreement and extended Russia’s individual sanctions for three years. Part of the compromise was removing several individuals who had been under sanctions since 2022. None came off through litigation. All were traded away in a room in Brussels, which makes the decision political...
OFAC GL 131J: Extended to October 22, With a Warning That It Can Be Revoked
A new date, and nothing else
On September 18, 2026, the Office of Foreign Assets Control (OFAC) issued a new general license (GL) under the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), codified at part 587 of title 31 of the Code of Federal Regulations (C.F.R.). OFAC GL 131J replaced GL 131I in its entirety, effective the day it was signed, one day before the earlier...
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 50 Percent Rule: When a Company Becomes Blocked
What the OFAC 50 percent rule actually says
The company is not on any sanctions list. The name screens clean, there are no hits, and it is registered in a perfectly ordinary jurisdiction. The transaction is still prohibited, and the payment will still be blocked. That is the OFAC 50 percent rule at work.
The statement of the rule is short. Any entity owned in the aggregate, directly or...
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...
OFAC GL 131I: Nine Licenses, a Signed Carlyle Deal, and Still No Approval for Lukoil
What changed in OFAC GL 131I
On August 20, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 131I under the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), 31 C.F.R. part 587.
We compared the texts line by line. Exactly one thing moved: the date. The authorization now runs through 12:01 a.m. Eastern Daylight...
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...