Economic Warfare & Trade Policy Sanctions
The Trump administration is reviewing a request from the Russian Direct Investment Fund (RDIF), Russia’s flagship sovereign investment fund, to be removed from the U.S. sanctions list, The New York Times reported on Tuesday, Oct. 27, 2026. As of Tuesday evening, the sanctions had not been lifted. The fund is still listed on the Treasury Department’s Specially Designated Nationals (SDN) list, and no decision has been announced.
According to the Times, which cited people familiar with talks between Moscow and Washington, Russian officials have pushed for the delisting as part of discussions about the fund’s role in shipping Russian diesel fuel to the United States. An unnamed U.S. official told the newspaper that the administration was assessing the fund’s application “through established procedures” as part of an effort to “improve U.S.-Russia relations and help end the war.” The same official called the fund’s chief executive, Kirill Dmitriev, “a helpful envoy” in the negotiations, according to the report.
What the RDIF sanctions review means
A review is not a decision. Under Treasury’s normal delisting process, a sanctioned entity that asks to be removed must show that the reasons for its original designation no longer apply, according to people familiar with the process cited by the Times. The Treasury Department, the Kremlin and RDIF had not issued public statements about a possible removal at the time of the report, according to Clash Report’s summary of the story.
The Office of Foreign Assets Control’s sanctions search tool still lists the fund’s management company, Joint Stock Company Management Company of the Russian Direct Investment Fund, as a blocked entity under the RUSSIA-EO14024 program. The listing notes a risk of secondary sanctions under Section 11 of Executive Order 14024, which can reach foreign banks that deal with designated Russian entities.
If the fund were delisted, it would be one of the most significant reversals of U.S. economic pressure on Russia since the full-scale invasion of Ukraine. RDIF has invested billions of dollars in Russian companies, often alongside partners from the Middle East and elsewhere.
Why Treasury sanctioned the fund in 2022
Treasury’s Office of Foreign Assets Control blocked RDIF, its management company and a subsidiary, LLC RVC Management Company, on Feb. 28, 2022, four days after Russian forces invaded Ukraine. In its announcement, Treasury wrote that “while officially a sovereign wealth fund, RDIF is widely considered a slush fund for President Vladimir Putin and is emblematic of Russia’s broader kleptocracy.”
The same action designated Dmitriev personally. Treasury described him as a close ally of Putin and said he had used ties to U.S. universities and organizations to act as a representative of the Russian president to American institutions. The fund was created in 2011 by order of then-President Dmitry Medvedev and then-Prime Minister Putin to attract foreign direct investment into Russia. Its best-known project was the Sputnik V COVID-19 vaccine. On the same day, Treasury also barred U.S. persons from transactions with Russia’s central bank, its National Wealth Fund and its Ministry of Finance.
The diesel deal behind the request
The request is tied to a diesel arrangement announced on Oct. 9, 2026. That day, OFAC issued Russia-related General License 135, which authorizes transactions related to the sale, delivery, offloading and importation of Russian-origin diesel fuel, including into the United States, through 12:01 a.m. Eastern time on April 7, 2027. The license does not authorize debits to U.S. bank accounts held by Russia’s central bank, National Wealth Fund or Ministry of Finance.
According to the Times, RDIF offered to handle transactions between Russian sellers and American buyers while asking to be taken off the sanctions list. Treasury’s position, the paper reported, is that the fund already has the authorization it needs to take part in diesel deals under the October license, so delisting is not required for shipments to go ahead. The Boston Report covered the first diesel shipments in its Oct. 27 geopolitics and business report.
Russian officials say three diesel tankers sailed for the United States this month. Russian Deputy Prime Minister Alexander Novak said on Oct. 23 that the shipments went ahead “with the significant support” of RDIF, according to the Kyiv Post. Ship-tracking data from Kpler and TankerTrackers.com cited in the reporting show one tanker, the Agioi Fanendes, leaving the port of Primorsk on Oct. 23, with arrival in the U.S. expected around Nov. 7. The vessel has since changed its listed destination from New York to “for orders,” meaning it has no discharge instructions yet. Some of the fuel left Russia before any U.S. buyer had paid for it, people familiar with the matter told the Times.
Legal questions and the wider talks
The diesel license has drawn legal questions. In an Oct. 9 client note, the law firm Herbert Smith Freehills Kramer pointed out that the license does not expressly address the Ending Importation of Russian Oil Act of 2022. That law bans U.S. imports of Russian energy products and sets out its own process for lifting the ban, including a presidential certification and a 90-day congressional review period.
The diesel announcement came about three weeks after the Lindsey O. Graham Sanctioning Russia and Iran Act was signed into law on Sept. 18, according to the Kyiv Post. Russian Foreign Minister Sergey Lavrov said on Oct. 27 that the diesel agreement was a commercial transaction with no political conditions attached. Peace negotiations over the war in Ukraine are continuing, as covered in The Boston Report’s Oct. 26 Ukraine war update and its report on Zelensky’s offer to freeze front lines.
Any removal of RDIF from the SDN list would be published on OFAC’s recent actions page. The Boston Report will update this story if Treasury announces a decision.
Sources
- U.S. Treasury: Treasury Prohibits Transactions with Central Bank of Russia and Imposes Sanctions on Key Sources of Russia’s Wealth (Feb. 28, 2022)
- OFAC Sanctions List Search: JSC Management Company of the Russian Direct Investment Fund
- OFAC: Issuance of Russia-related General License 135 (Oct. 9, 2026)
- OFAC: General License No. 135 text
- Kyiv Post: Trump Administration Weighs Lifting Sanctions on Kremlin’s Investment Fund (citing The New York Times)
Additional sources
- Meduza: Summary of The New York Times report on RDIF
- Clash Report: Status of the review and Lavrov’s Oct. 27 remarks
- Herbert Smith Freehills Kramer: Analysis of General License 135
- NBC News: Trump says Putin will release diesel fuel into global market (Oct. 9, 2026)
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