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...
Graham Russia Sanctions Act: Mandatory Designations, Tariffs and the New Route to Relief
The Graham Russia Sanctions Act was signed into law on September 18, 2026. It carries the name of Senator Lindsey Graham, who died on July 12, 2026, and did not live to see it enacted. For anyone already on the Specially Designated Nationals (SDN) List maintained by the Office of Foreign Assets Control (OFAC), or at risk of being added to it, the 500 percent tariff headlines are not the point....
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...
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...
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...
Changed Circumstances as Grounds for Removal from the SDN List
Among the individuals and entities named on the U.S. Treasury’s Specially Designated Nationals (SDN) List, maintained by the Office of Foreign Assets Control (OFAC), one question comes up more than any other: “My situation has changed, can I come off the list?” It is a fair question. A listing rarely reflects a person or company forever: businesses are sold, positions are vacated, controlling...