On 3 September 2025, the the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) of removed Belarusian citizen Iryna Litvinyuk from the Specially Designated Nationals and Blocked Persons List (SDN list). The decision was adopted after reviewing an administrative petition to reconsider the initial designation.

The uniqueness of the case lies in the fact that the removal from the SDN list of a person initially designated under the Global Magnitsky Human Rights Accountability Act occurred for the first time outside of Turkey, the Dominican Republic, the UAE and Hungary. This demonstrates OFAC's willingness to consider cases on their merits, even when the allegations relate to alleged “Russian influence”.

Roman Khaminskiy, Head of International Compliance at Orion, participated in the project and emphasised the significance of the decision:

“Sanctions measures are not final, and the appeal mechanism does work, even if a possible Russian factor is involved.”

This statement reflects the establishment of an important precedent in the practice of appealing sanctions restrictions through administrative process.

The Global Magnitsky Human Rights Accountability Act, on the basis of which Ms Litvinyuk was included in the SDN list, is directed against individuals guilty of serious human rights violations and corruption around the world. The successful appeal against the sanctions demonstrates the possibility of protecting rights even in the most complex international legal situations.