On November 4, 2025, VFC Solutions Ltd (“VFC”), a Cypriot investment and consulting company that was designated in the United States in 2023, filed a complaint against the U.S. Department of the Treasury’s Office of Foreign Assets Control and OFAC’s director Bradley T. Smith after OFAC denied the company’s delisting petition on September 19, 2025. VFC is seeking declaratory relief and injunctive relief and is requesting that the Court set aside the denial, reconsider the matter, and grant any additional relief that the Court might deem appropriate under the circumstances.
According to the complaint, VFC was sanctioned by OFAC on February 1, 2023 pursuant to Executive Order 14024 for being owned or controlled by Alexander Volfovich, a VFC executive at the time who was concurrently designated by OFAC for allegedly supporting Igor Zimenkov. According to OFAC, Zimenkov is a Russian Arms Dealer who was also designated on February 1, 2023 along with several alleged members of his network, including Volfovich’s adult children, Stanislav and Ariel Volfovich, who were designated on the same day for having a leadership role in VFC. These sanctions effectively blocked VFC’s property and interests in property in the United States and its ability to engage in transactions or dealings with U.S. persons. While the company reportedly generated between $2.5 to $5 million in annual revenues for three years prior to its designation, VFC has now ceased all commercial activities and has suffered a total loss of commercial revenues since its designation, according to the complaint.
In an effort to have VFC delisted, Alexander Volfovich resigned as VFC’s director on September 5, 2024 and tried to divest his VFC ownership shares in August 7, 2024 – an effort that, according to the complaint, was likely impeded by the Cyprus government due to the imposition of U.S. sanctions. However, OFAC reportedly denied VFC’s petition on the grounds that Alexander Volfovich might be able to indirectly control VFC through family members, despite his resignation and attempts to divest. In response, VFC filed the complaint challenging the denial on the grounds that it was based on “speculative and conclusory assertions” and conjecture rather than evidence – a move that, according to VFC, “constitutes an arbitrary and capricious agency action.” VFC also indicated that OFAC’s denial was based on alleged misstatements made by Alexander Volfovich in a separate delisting petition, which reportedly caused OFAC to question the trustworthiness of information provided by Volfovich in support of VFC’s remedial measures. VFC argued that, by wrongfully imputing Volfovich’s conduct to VFC, OFAC “misapplied its evidentiary standards” and violated the Administrative Procedure Act.
Complaint | U.S. Department of Treasury Press Release (February 1, 2023)