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LBKM successfully challenges OFAC’s designation of vessel erroneously linked to Russian oligarch

March 2024

Eric L. Lewis and Solomon Shinerock submitted a petition to the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) for immediate de-listing of a vessel from the Specially Designated Nationals and Blocked Persons (“SDN”) list. The vessel was listed pursuant to Executive Order 14024, relating to the Russian sanctions program, due to a misidentification of ownership. Specifically, we believed that the vessel was listed on the basis of a dated news article linking it to a sanctioned Russian oligarch.

In our petition, we demonstrated that the basis for reconsideration and delisting was straightforward. We showed the likely error in misidentifying the vessel’s owner as a sanctioned individual, and provided proof of bona fide ownership free and clear of any interest of sanctioned individuals. In fact, while the oligarch was the vessel’s original owner, we showed that he had transferred ownership of the vessel long before he was sanctioned in 2023 and had not been on the vessel in several years.  We also showed that the listing of the vessel had no impact on the oligarch or any other sanctioned individual, and did not further any U.S. foreign policy interest related to the Russian sanctions program or otherwise. To the contrary, we were able to demonstrate that the listing of the vessel caused economic and reputational harm to innocent parties, and presented a number of practical and economic risks faced by both the vessel’s innocent owners and U.S. interests that would follow-on from the crippling impact of the sanctions.

Following several months of follow-up advocacy, we received notice that OFAC was removing the vessel from the SDN list, allowing it to resume normal operations.

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