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Sanctions-Related Advocacy

With the onset of war in Ukraine, the United States, and its allies have implemented blocking sanctions against scores of entities, and individuals with ties to the Russian Federation, or its economy. The sanctions, administered in the United States by the Office of Foreign Asset Control (OFAC) effectively prohibit United States individuals, and entities from doing business with the subjects of sanctions. In many cases, individuals, and entities may be the subject of European, British, and/or Canadian sanctions even if they are not sanctioned in the United States. The Russian Federation has introduced reciprocal measures, making economic, or business dealings with exposure to Russia more complicated even if none of the participants involved are the subject of sanctions.

In addition to sanctions, several large institutions (including many blue-chip law firms) have made categorical decisions to abstain from any activity that involves the participation of Russian citizens, or entities.

Ford O’Brien Landy LLP has established a practice representing individuals, and entities whose business, and even ability to travel has been hindered by sanctions. Utilizing applicable OFAC general licenses, we represent sanctioned individuals, and entities in litigations pending in U.S. state and federal courts as well as arbitration. We assist individuals, and entities in getting OFAC designations removed, and coordinate with foreign counsel who address issues in other jurisdictions. We represent clients seeking specific OFAC licenses to consummate transactions that would otherwise be prohibited (including transactions relating to the winding down of Russian-facing business operations). We also assist individuals who are no longer able to travel to the United States due to their connections with sanctioned entities, or due to their inclusion on foreign sanctions lists, even if there are no applicable sanctions in the United States.