On February 22, 2022, the Office of Foreign Assets Control (OFAC)’s issuance of the related Directive 1A under the Executive Order on Blocking Property (EO 14024) pioneered a series of sanctions impacting various entities (notably commercial) under U.S. jurisdiction. In the spring of 2022, the Special Russian Sanctions Authority Act of 2022 was introduced in the Senate and ultimately signed into law, legalizing the expansion of the existing sanctions against the assets of Russian political elites since the onset of the Russia-Ukraine war. In analyzing the application of U.S. contract law, professional codes of conduct for U.S. attorneys, and the limits of U.S. jurisdiction as it concerns these government sanctions, one may discover limitations to the long list of sanctions against Russian entities and their enforceability.

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