CMS INDUSLAW secures India's first successful OFAC delisting for Lokesh Machines

CMS INDUSLAW has represented Lokesh Machines Limited in securing its removal from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) List.

The CMS INDUSLAW team was led by Faraz Alam Sagar (Partner & Head – Dispute Resolution and White-Collar Crime) and Surya Karan Sambyal (Partner), with support from Aarti Abhyankar (Senior Associate), Associates Aditi Goyal, Kinjal Sharma, Urja Dhapre, Prateek Ayyappan and Diya Choudhary.

Lokesh Machines was designated on 30 October 2024 under Executive Order 14024, OFAC’s Russia-related sanctions program, for allegedly operating in the manufacturing sector of the Russian Federation economy.

Through a comprehensive delisting petition challenging the designation on various grounds, CMS INDUSLAW secured the company’s removal from the SDN List on 30 June 2026 – marking India’s first successful delisting granted by OFAC.

The designation had significant consequences for Lokesh Machines Limited, including the blocking of assets within U.S. jurisdiction and restrictions on dealings with U.S. persons. CMS INDUSLAW worked closely with the company at every stage – conducting a detailed review of the designation, formulating the strategy, preparing the delisting petition before OFAC, and responding to OFAC’s follow-up questions – while challenging the grounds on which the designation had been made. CMS INDUSLAW co-counselled with U.S. law firm Blank Rome LLP to represent Lokesh Machines Limited’s interests before OFAC.

Beyond the petition itself, CMS INDUSLAW supported Lokesh Machines Limited across the full spectrum of the process, including business continuity, sanctions compliance, and training, to ensure the company was equipped to navigate the implications of the designation and safeguard its operations throughout.

Faraz Alam Sagar (Partner & Head – Dispute Resolution and White-Collar Crime) commented,

"This delisting marks the first removal of Indian companies from OFAC's Russia-related sanctions list since the 2024 designations. We're pleased to have secured this outcome for our client and to see Lokesh Machines Limited's name cleared from the SDN List. This result reinforces CMS INDUSLAW’s depth of experience and position as India's leading firm for international sanctions advisory in India.”

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