Marks & Sokolov Secures Dismissal of OFAC Sanctions–Based Defenses in California Court

 Marks & Sokolov is pleased to announce a significant litigation victory in the Superior Court of California.

The firm represents a Russian financial institution designated as a Specially Designated National (“SDN”) by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), in an action seeking recognition of over $1.5 billion Russian judgment. The action was brought pursuant to California’s Uniform Foreign-Country Money Judgment Recognition Act, Cal. Civ. Proc. Code §§ 1713 et seq.  (“Act”).  In 2025, Marks & Sokolov successfully applied for and obtained within one month, an OFAC license authorizing enforcement of the judgment.

In response to the Complaint, the defendant asserted Affirmative Defenses alleging that: (i) recognition of the Russian judgment was barred by U.S. sanctions under 31 C.F.R. § 587; and (ii) the OFAC License was invalid.

On March 5, 2026, the Court dismissed these defenses, holding that they are not recognized under the Act.  The Court reaffirmed its prior ruling in which it denied the defendant’s motion to dismiss and held that U.S. sanctions do not preclude recognition of the Russian judgment under the Act. It also held that any alleged defects in the issuance of the License are irrelevant to the recognition analysis. The Court also struck additional sanctions-related allegations as immaterial.

This ruling confirms that creditors may seek recognition  of foreign judgments in U.S. courts even if they are subject to sanctions.  By confirming that U.S. sanctions do not bar recognition under California law, this result assists cross-border debt recovery and strengthens creditors’ ability to recognize and enforce international judgments.

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