The Office of Foreign Assets Control (OFAC) is the primary agency responsible for monitoring and controlling assets that are potentially landing in the hands of bad global actors. Most importantly, the OFAC seeks to ensure that terrorists, drug dealers, and human traffickers aren’t being funded through business deals, trades, and other sources. The OFAC achieves this goal by enforcing economic sanctions against certain individuals and businesses.

While these entities are listed on the sanctions list, they aren’t able to trade or participate in foreign deals. If an American individual or group is discovered doing business with a sanctioned entity, then they could face serious criminal repercussions.

It is possible to be put on a sanctions list and then later de-listed. Just recently, the OFAC deleted specific Russia-related nationals from the sanctioned list. Among those that are now safe to conduct business with are:

• Emperor Aviation LTD
• Emperor Avieishn LTD
• 9H-AMN
• 9H-ARK
• 9H-EAA
• 9H-MAO
• 9H-SIS
• 9H-SSK
• 9H-TIO

Many of these de-sanctioned entities are specific aircraft. Emperor Aviation was put on the sanctions list, along with these aircraft, back in 2022. According to the OFAC, the company and the aircraft were all accused of facilitating travel for a previously sanctioned individual, Suleiman Kerimov, and his family. Kerimov is an oligarch and big stakeholder for Uralkali and Gazprom. Kerimov has been personally sanctioned by the OFAC twice. In 2018, he was sanctioned for being a known Russian government official, and in 2022 he was sanctioned again for his unique connections to a specific government-backed corporate business.

These sanctions were legitimized under Executive Order 14024 because the entity assisted and provided support or goods or services in support of Gulnara.

As of now, the OFAC hasn’t given any reason for the removal of these entities.

Remaining Compliant with OFAC Sanctions and Other Global Laws

Does your business regularly facilitate global deals? If so, then you likely already know how difficult it is to remain compliant with not only OFAC sanctions but also other global laws and regulations that dictate the way you need to trade.

Despite all the complexities of the law, you must ensure you’re compliant. Violating an OFAC sanction has severe consequences. If you accidentally conduct business with a sanctioned entity, then you could face prison time of up to 30 years and fines that potentially reach millions of dollars.

Here at Bukh Global, our team of highly skilled and qualified global attorneys understand the unique challenges your business is facing when attempting to conduct international trade. If you’re concerned about the law in not only America but in other areas that you do business, then we can help. Our team can also provide solid legal counsel for you and your business if you’ve already been accused of violating OFAC sanctions or breaking another law.

Schedule a call with our office now to discuss your specific legal needs with one of our best attorneys. Together, we’ll make sure your business is up to the proper legal standard everywhere you conduct business.