On July 18, 2025, Aleksandr Okulov – who was designated by the U.S. Office of Foreign Assets Control as a Specially Designated National in April 2022 – filed a lawsuit disputing the designation and OFAC’s “prolonged failure” to adjudicate his request to have it rescinded. The Russian-Moldovan national who currently lives in Dubai was sanctioned on April 20, 2022 pursuant to Executive Order 14024 for, among other things, providing assistance to Russian oligarch Konstantin Malofeyev and travelling with Malofeyev to Africa as a supervisory board member of a sanctioned organization that Malofeyev operates. Malofeyev was sanctioned by OFAC in 2014 pursuant to EO 14024 for supporting Russian separatists in Crimea, and then again in 2022 for supporting pro-Russian activities in various countries.
According to the complaint, Okulov filed an application to have these sanctions rescinded on June 13, 2024, explaining that, while he had a “limited and intermittent acquaintance” with Malofeyev between 2019 and 2022, he never participated in his political activities. He also admitted that he unsuccessfully sought funding from Malofeyev for a legitimate business venture that had no connection to Russian foreign policy and, since that time, has allegedly ceased all contact with Malofeyev. Okulov further argued that, while he was born in the former Soviet Union, he has never lived or worked in Russia and is reportedly in the process of renouncing his Russian citizenship. He also indicated that rather than supporting the Russian aggression in Ukraine, he made charitable contributions to the City of Kramatorsk in eastern Ukraine – a city that was severely damaged during Russian invasions in 2014 and 2022.
Okulov alleges in the complaint that, after filing his application for rescission of sanctions, he received a detailed questionnaire from OFAC on June 21, 2024, which he allegedly completed and returned to OFAC on August 27, 2024. Okulov claims that, since submitting the questionnaire, he has not received another questionnaire from OFAC and has not received any updates regarding his case.
Complaint for Declaratory and Injunctive Relief