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...
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....
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...
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...
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...
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...
Russia Sanctions Delisting: Who OFAC Removed from the SDN List on June 24, 2026
What Happened on June 24, 2026
On June 24, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published a routine update to the Specially Designated Nationals and Blocked Persons List (SDN List), removing seven individuals, two Russian-flagged cargo vessels, and two Turkish legal entities. All were designated under the RUSSIA-EO14024 sanctions program,...
Indirect OFAC Sanctions Violation: How a VTB Scheme Through a Law Firm Led to a $1M Penalty
The Case: What FTI Did
On June 1, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) released an enforcement action against FTI Consulting, Inc. (FTI), a Washington, D.C.-based international advisory firm. FTI agreed to pay $1,050,000 to resolve its potential civil liability for apparent violations of U.S. sanctions targeting Russia's financial sector....
Challenging OFAC Sanctions in Court: The Albanese Case and the D.D.C. Preliminary Injunction
On May 13, 2026, the U.S. District Court for the District of Columbia (D.D.C.) issued a preliminary injunction in L.C. et al. v. Trump (L.C. v. Trump), suspending sanctions enforcement against Francesca Albanese, a United Nations Special Rapporteur on Human Rights. The case has become a landmark example of challenging OFAC sanctions in court: the court blocked enforcement of a decision by the...