Alert: important development in OFAC sanctions intersection with Russian asset recovery strategy for Emirati creditors

Alert: important development in OFAC sanctions intersection with Russian asset recovery strategy for Emirati creditors Effective: 15 April 2027

Emirati creditors pursuing asset recovery against Russian counterparties must now account for a tightening in the intersection between US OFAC sanctions compliance and the mechanics of Russian civil enforcement – an intersection that neither Russian law nor UAE domestic law resolves on its own. Creditors who have structured their recovery strategy under Russian law alone may find that execution steps which are entirely lawful under Russian procedure nonetheless engage OFAC licensing obligations where the creditor entity or its banking correspondents have exposure to the US financial system.

Emirati companies and family offices holding Russian trade debts, pledge security, or insolvency claims are directly in scope if their banking relationships run through US dollar correspondent accounts or if their holding structures include US-person elements. In those circumstances, receiving a payment – including a court-enforced transfer from a Russian debtor's account – may constitute a transaction requiring OFAC authorisation, regardless of whether the underlying Russian court order is entirely valid. Russian counsel can confirm the lawfulness of each step under Russian law; whether a given receipt of funds is permissible under OFAC's current framework is a question for US-qualified sanctions counsel, and the two analyses must run in parallel.

Recommended action:

1. Audit your recovery structure before the next enforcement step. Identify whether any element of the payment chain – correspondent bank, holding entity, or nominee – has US-person exposure that could bring OFAC into scope.
2. Instruct Russian law counsel to confirm which procedural steps are available and their sequencing, so that the Russian-law timeline is clear before US sanctions counsel assesses each step.
3. Obtain a written OFAC compliance position from US-qualified sanctions counsel before executing any transfer from a Russian account, pledged asset realisation, or insolvency distribution.
4. Review whether a specific licence application to OFAC is necessary and, if so, factor the processing timeline into your overall recovery schedule.

For a review of the Russian-law dimension of your recovery position – including asset identification, enforcement mechanics under Russian civil procedure, and insolvency creditor strategy – contact the asset tracing and recovery team at Vetrov & Partners. We work alongside your OFAC and UAE counsel to ensure the Russian-law steps are sequenced correctly.

Make an enquiry — info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

Further reading: Asset Tracing & Recovery | OFAC sanctions intersection with Russian asset recovery strategy | Federal Tax Service guidance: OFAC intersection

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors – including Emirati, European, and Asian trade creditors – on Russian enforcement, pledge realisation, and insolvency creditor strategy.

Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

— Elizaveta Razina Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners vetrovpartners.com/razina/