On June 24, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) officially removed Nadiya Cherkasova, Irina Kremleva, and Viktor Nikolaev from the Specially Designated Nationals and Blocked Persons (SDN) List. These three were Akrivis Law Group, PLLC’s cases. They were among a number of parties designated under Executive Order (E.O.) 14024 (April 15, 2021) who were delisted that day.
Ms. Nadia Cherkasova is a former member of the Executive Board of Bank Otkritie Financial Corporation (“Bank Otkritie”). Ms. Irina Kremleva is a former member of the Executive Board and Chief Risk Officer of Bank Otkritie. Mr. Viktor Nikolaev is a former member of the Executive Board and the Head of the Corporate and Investment Unit of Bank Otkritie. Ms. Cherkasova, Ms. Kremleva, and Mr. Nikolaev were all designated by OFAC in 2022 under E.O. 14024 due to their positions at Bank Otkritie, which was also designated in 2022 under E.O. 14024. Notably, however, the announcement to list these parties in 2022 was made by the U.S. Department of State, which has named others to the SDN List as well.
The authority under E.O. 14024 has been used extensively to target individuals and entities following the Russian invasion of Ukraine in February 2022. Among the categories of entities blocked by OFAC and the U.S. Department of State under this authority are those operating in the financial services sector of the Russian Federation economy.
Individuals designated onto the SDN List are prohibited from virtually all dealings with the United States and with U.S. persons, with their assets under U.S. jurisdiction being subject to blocking. While these limitations are legally limited to the United States and U.S. economy, such designations invariably lead to a cascading effect whereby the individual is effectively blocked from transactions around the world – such individuals are often denied banking services by even foreign, non-U.S. banks, even if local laws do not prohibit such activities.
The successful delistings are among several high-profile removals Akrivis Law Group has secured in recent years, reinforcing its position as a leading firm in the field of U.S. sanctions and export control laws. The legal team representing Ms. Cherkasova, Ms. Kremleva, and Mr. Nikolaev was led by Akrivis Law Group Managing Partner Farhad Alavi and Partner Sam Amir Toossi.
An international trade compliance (sanctions, export controls, customs, anti-corruption) and defense lawyer.
U.S. Sanctions Regulations Blog 
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