Sanctions 04 Jan, 2019 Russian Sanctions - Rusal - Intention to Remove from SDN List Further to our previous News Items concerning the impact of U.S. sanctions on major Russia aluminium trader Rusal (most recently on 17 December 2018 ), OFAC has notified Congress of their intention to remove Rusal and some associated companies from the U.S. SDN list by 21 January 2019 following significant changes made to Rusal's shareholdings and structure. As and when that occurs Members will be at liberty to trade freely with Rusal and will not be subject to the current wind-down provisions. As the latest Client Alert from the Club's U.S. attorneys Freehill Hogan & Mahar makes clear, however, the current partial shutdown of the U.S. Government over budgetary disputes may be impacting OFAC's ability to actually implement the changes. As always, Members with specific questions concerning these measures and any other sanctions matters should contact the Managers.