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...
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 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...
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....
Lukoil Sanctions: OFAC Issues GL 131D, Extending the Sale Window for Lukoil International GmbH Through May 1, 2026
On March 30, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) issued General License No. 131D (GL 131D), replacing GL 131C, which was set to expire on April 1, 2026. The new license extends through May 1, 2026, the authorization to negotiate and enter into contingent contracts for the sale of Lukoil International GmbH (“LIG”), the Austrian holding...
Sanctions on Russian Oil: OFAC Amends GL 134
On March 19, 2026, exactly one week after issuing GL 134, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published General License GL 134A, which superseded GL 134 on the same date. The core authorization covering sanctions on Russian oil remains intact: GL 134A still permits the sale, transport, and offloading of Russian petroleum and petroleum products loaded...
The 50 Percent Rule and Controlling Blocked Persons
Introduction
The 50 Percent Rule is one of the critical points of the US sanctions policy. It helps to understand how US sanctions work, whom they primarily target, and who falls under them.
US Sanctions and the 50 Percent Rule
Not only do those individuals and companies on the US sanctions list fall under US sanctions, but also those entities in which blocked persons own 50 percent or...