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...
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....
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...
Inheritance from Russia to the US: How to Claim It and Get the Money to Your Account
Four barriers, and only two of them are American
An inheritance from Russia to the US rarely arrives on a lawyer’s desk as a question of law. It arrives as a wire that did not land, a bank that has asked for documents nobody kept, or a client who has just discovered that the six-month window closed four months ago.
It helps to separate four barriers that operate independently of one...
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 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...
Indian Companies Delisting: OFAC Removes Four Firms from the SDN List
What Happened on June 30, 2026
On June 30, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed four Indian companies from the Specially Designated Nationals and Blocked Persons List (SDN List) under the RUSSIA-EO14024 program. This Indian companies delisting covered RRG Engineering Technologies Private Limited and Lokesh Machines Limited (both based in...
OFAC Removes Turkish Sanctions Evasion Network from Russia-Related SDN List
What Happened on June 29, 2026
On June 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed seven entries from the Specially Designated Nationals and Blocked Persons List (SDN List) under the RUSSIA-EO14024 program. All seven are Turkish companies and individuals previously designated for supporting Russia's military-industrial base through sanctions...