Petr Aven brings US claim against OFAC for failure to delist him from US Russia sanctions

1 October 2026

Petr Olegovich Aven has issued a claim in the District Court for the District of Columbia against the Office of Foreign Assets Control for not delisting him from the EO 14024 Russia sanctions harmful activities list.

Mr. Aven was listed in August 2023 for “operating or having operated in the financial services sector of the Russian economy” by serving on the supervisory board of the Alfa Group Consortium, and as chairman of the board of a Russia-based insurance company. He applied to be delisted in April 2025 on the grounds that since December 2024 he had fully divested his interests in the Alfa Group Consortium companies and had resigned from all management positions with Russian entities.

Mr. Aven now asks the Court to declare that OFAC’s failure to act on the delisting application for over 17 months and/or his continued designation are unlawful under 5 U.S. Code § 706 contrary to the Administrative Procedure Act. § 706 requires US courts to compel agency action that is unreasonably delayed, and to declare unlawful and set aside action that exceeds an agency's statutory authority (if it is arbitrary, capricious or an abuse of discretion).

He asks for an injunction requiring OFAC to provide a final written decision on his designation or delist him because:

• OFAC unreasonably delayed by not making a delisting decision despite having sufficient evidence to do so.
• The basis for his designation is no longer correct because of his divestments and resignations. To continue the designation because of Mr. Aven’s past conduct would undermine OFAC’s policy that sanctions are meant to change behaviour, and not to punish past behaviour. OFAC’s failure to examine Mr. Aven’s changed behaviour and to act on it is an abuse of its discretion.
• OFAC delisted people sanctioned for similar reasons to Mr. Aven when they severed their connections with Russian financial services. His differential treatment by OFAC is arbitrary and capricious.

See our US delisting pages for more information on the US delisting process and delisting legislation.