Russia Sanctions Lawyer
Expert legal counsel for US sanctions on Russia, OFAC compliance under Executive Order 14024, sectoral sanctions defense, and SDN list issues. Protecting your business in a rapidly evolving sanctions environment.
US Sanctions on Russia: What You Need to Know
The United States maintains one of the most comprehensive sanctions regimes against Russia, administered by the Office of Foreign Assets Control (OFAC) under the U.S. Department of the Treasury. Following Russia’s invasion of Ukraine, these sanctions have expanded dramatically, with Executive Order 14024 forming the backbone of the current Russia sanctions architecture. The Specially Designated Nationals (SDN) list, sectoral sanctions targeting energy, finance, and defense industries, and secondary sanctions affecting third-country entities have created a complex legal landscape that requires specialized legal counsel to navigate.
The Sanctioning Russia Act of 2025 introduced the possibility of 500% tariffs on imports from countries purchasing Russian oil, gas, or uranium — a significant escalation with global trade implications. Meanwhile, OFAC designated major Russian energy firms including Lukoil and Rosneft subsidiaries, targeting Russia’s war-financing capacity. In 2025 alone, OFAC issued 14 enforcement actions related to Russia sanctions, totaling over $265 million in civil penalties.
How Our Russia Sanctions Lawyers Help
Our attorneys provide comprehensive legal representation for businesses and individuals facing Russia sanctions issues — from initial compliance reviews to OFAC enforcement defense. Whether you are a multinational corporation with Russian counterparties, an energy sector firm navigating sectoral sanctions, or an individual facing designation risk, we provide strategic legal counsel at every stage.
- SDN List Screening & Compliance Audits: Reviewing counterparty relationships for OFAC exposure under the 50% ownership rule and sectoral sanctions
- OFAC License Applications: Drafting and submitting specific licenses for authorized transactions involving Russia-related sanctions programs
- Voluntary Self-Disclosure (VSD): Preparing and submitting VSDs to OFAC to mitigate penalties for apparent violations
- Enforcement Defense: Representing clients in OFAC investigations, penalty negotiations, and settlement proceedings
- Secondary Sanctions Risk Assessment: Advising non-U.S. entities on extraterritorial exposure and compliance strategies
- Sanctions Compliance Program Development: Building robust internal controls to prevent Russia sanctions violations
⚡ Quick Answer
A Russia sanctions lawyer helps businesses and individuals navigate OFAC’s Russia sanctions programs, including the SDN list, sectoral sanctions under Executive Order 14024, and secondary sanctions. Legal counsel is essential when your company has Russian counterparties, conducts transactions in sanctioned sectors (energy, finance, defense), or faces an OFAC investigation. Given 2025 enforcement totaling $265M+ in Russia-related penalties and the introduction of the Sanctioning Russia Act, professional legal guidance is critical to avoid severe civil and criminal penalties.
Russia Sanctions Programs: Key Legal Frameworks
OFAC administers Russia-related sanctions under multiple overlapping legal authorities. Understanding which program applies to your situation is the first step in any compliance or defense strategy:
Executive Order 14024
The primary authority for Russia sanctions since 2021, EO 14024 authorizes blocking of property of persons who operate in sectors of the Russian economy, engage in deceptive practices supporting Russia, or provide material support to the Russian government. Subsidiaries and entities 50% or more owned by SDN-listed parties are automatically blocked, even without explicit designation.
Sectoral Sanctions
Unlike full SDN designations, sectoral sanctions under Directives 1-6 restrict specific types of dealings with identified Russian entities — particularly in energy, finance, and defense sectors. These prohibit new equity or debt financing, certain project involvement, and provision of goods and services to named entities and their subsidiaries.
Secondary Sanctions Risk
Foreign financial institutions and businesses that facilitate significant transactions with sanctioned Russian entities risk secondary sanctions — including loss of access to U.S. financial markets. The DROP Act of 2026 further tightens restrictions on buyers of Russian oil via the “shadow fleet,” creating significant exposure for non-U.S. companies.
Common Russia Sanctions Violations We Defend
OFAC’s “substance over form” doctrine means that structuring transactions through intermediaries does not insulate parties from liability. Common scenarios leading to Russia sanctions violations include:
- Financial transactions with Russian oligarchs or their family members through third-party intermediaries
- Energy deals involving Russian oil or natural gas that indirectly benefit sanctioned entities
- Real estate or investment transactions that fail to identify underlying Russian beneficial owners
- Correspondent banking relationships that inadvertently process Russia-sanctioned transactions
- Failure to report blocked property to OFAC within the required 10-business-day window
Free Consultation with a Russia Sanctions Lawyer
Russia sanctions law is one of the most rapidly evolving areas of U.S. economic sanctions. New designations, executive orders, and enforcement actions are issued frequently. Our team monitors these developments daily and advises clients on immediate compliance steps. Contact our Russia sanctions lawyers for a confidential consultation to assess your legal exposure and develop a strategic compliance or defense plan.
What US sanctions apply to Russia?
The US maintains comprehensive Russia sanctions under Executive Order 14024, the Countering America’s Adversaries Through Sanctions Act (CAATSA), and multiple OFAC programs. These include SDN designations, sectoral sanctions targeting energy, finance, and defense sectors, and secondary sanctions on foreign entities facilitating Russia’s military or economic capacity. The Sanctioning Russia Act of 2025 added potential 500% tariffs on countries that purchase Russian oil or uranium.
Do Russia sanctions apply to non-US companies?
Yes. Secondary sanctions under EO 14024 can target foreign financial institutions and entities that conduct significant transactions with sanctioned Russian parties. Additionally, non-US companies processing transactions through US financial infrastructure or involving US persons remain subject to OFAC jurisdiction. Legal counsel is essential for non-US businesses with Russia exposure.
What is the 50% rule under Russia sanctions?
OFAC’s 50% rule provides that any entity 50% or more owned (directly or indirectly) by an SDN-listed party is itself considered blocked, even if not explicitly listed on the SDN list. This significantly expands the universe of prohibited counterparties beyond named entities and requires careful due diligence on beneficial ownership structures.
Can I get an OFAC license for Russia-related transactions?
OFAC issues specific licenses authorizing otherwise prohibited transactions on a case-by-case basis. Common license categories for Russia-related transactions include humanitarian transactions, legal fees for SDN-listed parties, and winding down existing contracts. Our Russia sanctions lawyers evaluate whether your transaction qualifies and prepare comprehensive license applications.
What should I do if I discover a possible Russia sanctions violation?
Act immediately. Stop the violating conduct, preserve all relevant records, and consult a Russia sanctions attorney before taking any further action. Carefully evaluate whether voluntary self-disclosure to OFAC is appropriate — a timely, comprehensive VSD can reduce civil penalties by 50% or more. Do not communicate with counterparties about the violation without legal counsel.