A New Round of Designations Every 180 Days

Russia-related designations came in waves before the Graham Act too, but their timing was a matter of policy. The Act puts them on a statutory schedule. Every 180 days, the President must reassess the persons and vessels that meet its criteria and sanction those that do. The first review is due around October 18, 2026, and the next roughly six months after that.

The Act does let the President waive sanctions in the US national interest. A waiver, however, requires a written justification to Congress, and no private individual should count on one.

For Russian nationals, there is one more point. A Russian citizen or company designated under the Act’s statutory restrictions faces a steep climb back: relief is tied to a peace agreement accepted by Ukraine, followed by congressional review.

The question that matters now is not how to get off the US sanctions list, but how to stay off it in the first place.

Who Should Assess Their Risk Now

The Act names several categories outright:

• oligarchs who have “not demonstrated opposition” to the war or continue to benefit from ties to the Russian government,
• executives, board members and major shareholders of defense, energy and transportation companies that support the Russian military,
• owners, operators, masters and insurers of vessels carrying Russian oil, gas or coal in evasion of sanctions,
• foreign banks that conduct significant transactions with sanctioned Russian banks.

The risk does not stop at that list. Existing sanctions programs remain in force, and in practice the exposure reaches people who would never describe themselves as targets:

• companies in the UAE, Turkey, India, China and elsewhere that sell dual-use goods to Russia or service those shipments,
• former executives and shareholders whose names still sit in corporate registries next to sanctioned companies,
• business partners and relatives of designated persons whom US authorities may see as a channel for moving assets,
• shipowners and managers whose vessels have called at Russian ports or taken part in ship-to-ship transfers.

US sanctions follow conduct and connections, not passports.

Where the Grounds for Designation Come From

Before a designation, neither OFAC nor the State Department notifies the person or company that it is preparing a decision, nor do they invite an explanation in advance. The grounds for designation are developed through an internal investigation and set out in an evidentiary memorandum: an internal document that makes the case that the person meets the relevant sanctions criteria.

The memorandum draws on open sources (corporate registries, press reports, investigative journalism, company and vessel data) and on information from US and foreign government agencies, some of which may remain classified. Most people learn of their designation only after the decision has been made, from the update to the sanctions list and the accompanying public announcement by OFAC or the State Department.

That has a practical consequence. The public record about you is, to a large extent, your file as US authorities see it. A registry still lists you as a director of a company you left three years ago. The press keeps quoting an old interview. A former employer’s website still carries your biography. All of it counts against you.

Staying off the US sanctions list starts with looking at yourself the way the author of that memorandum would. We review your public footprint across registries, media, and commercial databases, the same kinds of material OFAC relies on (other than non-public sources). Information that is outdated or wrong can often be lawfully corrected: a registry entry amended, a publication asked to run a correction, corporate records brought up to date. Where the information is accurate, cosmetic fixes will not help. Real change will.

Ending Risky Ties: Making It Real

The most reliable way to stay off the US sanctions list is to stop meeting the criteria for designation. In practice, that means selling a stake, leaving a board, ending particular supplies, or winding down dealings with sanctioned counterparties and banks.

An exit only works if it is genuine. In its March 31, 2026 advisory on sham transactions, OFAC warned that a change of ownership on paper, where the former owner keeps control or the benefit, does not take a company outside the reach of sanctions. Handing a stake to a relative, a business partner, or a nominee does not reduce the risk. It creates a new one.

To withstand scrutiny, an exit should:

• be made at a market price, with real payment,
• go to a buyer with no connection to the seller,
• end influence as well as ownership, with no buy-back options, “adviser” roles, or informal management,
• be documented at every step: the agreement, the payment, the registry change, the corporate minutes.

Timing is decisive. Once a person is designated, their property subject to US jurisdiction is blocked, and US persons and banks cannot deal in it without an OFAC license. An exit that would have taken a few weeks a month earlier can become impossible.

OFAC looks past whose name is on the register to who actually controls the asset and takes the benefit.

An Evidence File in Case of Designation

Even well-built protection comes with no guarantee. The second half of the work is assembling, in advance, the documents that will be needed if designation happens anyway.

The file typically covers the history of your wealth, documents showing when and how you left stakes and positions, contracts and correspondence that show the real nature of any relationship with designated persons, and responses to publications that could be used against you. Everything should be translated and put into a form ready for submission.

Here is why it matters. If you are designated, the delisting petition has to be prepared quickly, and the first submission to OFAC becomes part of the administrative record a court may later review. Documents gathered in a hurry after the assets are frozen take longer to collect and carry less weight. For non-Russian persons, the Graham Act ties relief to showing that the conduct has ended, and the file becomes the backbone of that showing. The same material also answers the questions banks ask.

An evidence file is built before designation, not after it.

Screening Counterparties and Payments

If you still do business with Russia or with Russian partners, sanctions screening has to be continuous rather than a one-off exercise. Every new round of additions to the US sanctions list changes the picture: a reliable counterparty today may be designated tomorrow, and its subsidiaries blocked under the 50 percent rule.

The minimum:

• screen counterparties and their owners before every significant transaction and after every round of designations,
• include sanctions clauses that allow a contract to be suspended or terminated if the counterparty is designated,
• check the payment route: which banks the money passes through and whether any of them are sanctioned,
• keep a record of every check, so you can show later that the screening was done.

In a small company with a simple structure, a trained employee can handle this. Complex chains and large transactions are better reviewed with a lawyer who knows how OFAC will read those checks.