Diegelmann v. Bessent, No. 24-5277 (D.C. Cir. 2026, USG/OFAC Brief)

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TURBOFAC Commentary (322 words)

Consolidated Comment on Diegelmann v. Bessent, No. 24-5277 (D.C. Cir. 2026) - Opinion and Diegelmann v. Bessent, No. 24-5277 (D.C. Cir. 2026) - Diegelmann v. Bessent, No. 24-5277 (D.C. Cir. 2026, /OFAC Brief)

1) On 2-23-24, OFAC designated “German nationals Axel Paul Diegelmann (Axel) and Fritz Diegelmann (Fritz)” for having “collaborated with Russia-based metals companies to disguise the origin of Russian precious metals,” and in so doing “operating or having operated in the metals and mining sector of the Russian Federation economy” (see https://home.treasury.gov/news/press-releases/jy2117). Because OFAC alleged evasive conduct “disguis[ing] the origin,” this would not qualify as an ordinary “secondary sanctions” action, but the challenge is nonetheless notable because it based on arguments that OFAC’s “operating in” designation criterion, as interpreted by its FAQs, did not reach to the “procurement” of geological materials (and, alternatively,...

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Diegelmann v. Bessent, No. 24-5277 (D.C. Cir. 2026, USG/OFAC Brief)

TURBOFAC Commentary (322 words)