Articles Posted in Specially Designated National (SDN)

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On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions for Russia’s energy sector, designating Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil) under Executive Order (EO) 14024 as Specially Designated Nationals (SDNs), along with dozens of directly named subsidiaries.

These designations prohibit transactions with and services related to Rosneft, Lukoil, any entity that they or other SDNs own 50 percent or more, or any property in which such entities have an interest, directly or indirectly, for U.S. persons and where U.S. primary sanctions jurisdiction otherwise applies.

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On May 8, 2022, the White House announced a number of new measures in response to Russia’s ongoing war in Ukraine. The new measures include prohibitions on new categories of services to Russia by U.S. persons; export controls on certain industrial goods; and the addition of several shipping companies, bank executives, and television companies to the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) List.

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The listing of Specially Designated Nationals (SDNs) has the potential to impact any American doing business with a named party, including landlords who lease real estate to sanctioned persons. In “Specially Designated Nationals as Tenants: How Landlords Can Be Impacted by Sanctions Against Russian Nationals,” Nancy A. Fischer, Rachel B. Horsch, Anne C. Lefever, Zachary C. Rozen and Samantha Franks explain how sanctions designations may require U.S. persons involved with sanctioned individuals to terminate existing contracts, including leases, and why it is important for landlords to conduct thorough due diligence on prospective tenants and to negotiate language that enables them to quickly terminate a lease if a tenant becomes subject to sanctions.