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 Penalty for Sanctions Violations: What Actually Reduces the Amount
The Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) does not have to prove intent. Liability attaches to the act itself: the payment cleared, the goods shipped, the account was serviced. Intent affects how much a company pays, not whether it is liable at all.
Violations also rarely look like deliberate evasion. More often they come from an ownership stake...
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...
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...
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 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...
Source of Funds for a US Business: What US Banks Check for Russian Clients
Source of funds vs. source of wealth: two different questions
Bank compliance teams work with two related but distinct concepts. Source of funds is the origin of a specific sum moving through a specific transaction, say, a $200,000 wire into a new company's account. Source of wealth is the origin of a client's entire net worth: how the person built the fortune of which this transaction is...