Sanctions Architecture
OFAC, CAATSA, and Secondary Sanctions
Western sanctions on Russia operate through multiple legal frameworks. The primary US mechanism is OFAC (Office of Foreign Assets Control) sanctions under executive orders, which designate Russian entities (banks, oil companies, individuals) as blocked persons. CAATSA (Countering America's Adversaries Through Sanctions Act, 2017) provides the legal basis for secondary sanctions — penalising third-country entities that engage in "significant transactions" with sanctioned Russian defence and intelligence entities. The Rosneft and Lukoil sanctions (November 2025) are sectoral sanctions targeting Russia's energy revenue.
- CAATSA enacted: August 2017 (covers Russia, Iran, North Korea); signed by Trump in his first term
- India's S-400 missile system: purchased from Russia despite CAATSA risk; India was granted a waiver by the Biden administration (2022) citing India's unique strategic situation
- OFAC SDN (Specially Designated Nationals) list: entities on this list cannot transact with US persons or access dollar-clearing systems — creating a "secondary sanctions" risk for Indian banks processing Russian oil payments
- Oil payment mechanisms: India has increasingly used rupee-ruble trade and UAE dirhams to settle Russian oil payments, reducing dollar-clearing exposure
● Tracked since March 07, 2026 · last seen September 13, 2026 · updates as the daily brief publishes