Buying Finished Gold Bars from Russian Nationals Is “Procuring Geological Materials” Under US Sanctions Law: DC Circuit Upholds OFAC Sanctions on Diegelmann Traders
The dispute arose from Office of Foreign Assets Control (OFAC) sanctions imposed on German nationals engaged in the precious-metals trade for their alleged involvement with Russia-based metals companies. The appeal presented questions regarding the interpretation of the Russia metals and mining sanctions regime and the evidentiary basis for OFAC’s determination.