COLUMN: Washington Quietly Removes Names from the SDN List — While Ukraine Bleeds

Trump, Iran, and Trade Alliances to Be Strengthened

These removals do not come out of nowhere. They are part of the diplomatic strategy following the June 17, 2026, U.S.-Iran agreement. Donald Trump is seeking to strengthen trade alliances amid the normalization of tensions with Tehran—a process that involves recalibrating relations with countries such as Turkey and India, key players in the region. The lifting of sanctions on Indian and Turkish companies can be interpreted as a gesture of goodwill toward these partners—a signal that Washington is prepared to use the SDN list as a bargaining chip in regional diplomacy.

If this interpretation is correct, it is troubling for Ukraine. It means that sanctions against Russia—a tool designed to punish aggression and fund the Ukrainian resistance—are becoming a bargaining chip in a broader foreign policy that does not necessarily prioritize Ukraine. Trump has always had a holistic view of foreign policy: Ukraine is a piece on the chessboard, not the main objective. And when the pieces are moved for other reasons—the Iran deal, trade alliances, the balance of oil prices—Ukraine bears the consequences.

Lost Coherence: Sanctioning Rosneft, Freeing Its Intermediaries

The internal contradiction in U.S. policy is particularly striking in the sequence of events from June 17–24, 2026. On June 17, sanctions on Russian oil were reinstated—directly targeting Rosneft and Lukoil. On June 24, Washington removed from the SDN list individuals and entities linked to the financial networks that fuel the Russian war economy. On the one hand, the main valve is being shut off. On the other, a few secondary pipes are being reopened. This may not be coordinated internally in this way—sanctions decisions involve multiple agencies and may not be consistent with one another. But the cumulative effect, as seen from Kyiv or Brussels, is that of an incoherent policy.

This inconsistency is not merely a practical issue regarding the effectiveness of sanctions. It is a matter of credibility. The credibility of a sanctions regime rests on the certainty that the rules are applied consistently and predictably. If companies and individuals know that a designation can be lifted unconditionally, at any time, for opaque diplomatic reasons, they will act accordingly. And their calculation will be: the risk of remaining in the Russian network is manageable, temporary, and negotiable. This calculation is the opposite of the intended deterrent effect.

Imposing sanctions with the right hand, lifting them with the left. Washington’s inconsistency is not a bureaucratic accident—it is a structural feature of a policy that does not treat Ukraine as its top priority. And we must have the courage to say so.

The Ukrainian Watchdog: Vlasyuk and His Teams

Ukraine’s resilience in the face of sanctions is one of the least discussed aspects of this war. Commissioner Vlasyuk’s office monitors every change to the SDN list, every update to the OFAC registries, and every fluctuation in Russian oil flows. This real-time monitoring has become an international benchmark—journalists, researchers, and governments consult Ukrainian analyses to understand what is happening behind the scenes of U.S. sanctions. It is a remarkable reversal: Ukraine, under bombardment, has become a global center of expertise on sanctions against its own invader.

This expertise has immediate practical value: it allows Kyiv to publicly document U.S. decisions that Washington does not disclose, creating indirect pressure for transparency on the U.S. government. When Vlasyuk’s office confirms the reinstatement of oil sanctions before any official U.S. announcement, it implicitly forces Washington to acknowledge the decision. This use of transparency as a tool for diplomatic pressure is subtle but effective.

What Ukraine Is Asking For: Standards, Not Exceptions

Ukraine’s demand regarding sanctions is precisely articulated. Kyiv is not asking Washington to keep entities on the SDN list indefinitely. It is asking that removals be based on clear and public criteria: evidence of a change in behavior, cooperation with investigations into violations, and a documented cessation of problematic activities. And it demands that these criteria be publicly announced, so that decisions are subject to a minimum of democratic scrutiny. These requirements are not revolutionary. They are the bare minimum expected of a sanctions policy that claims to be serious.

In this context, the lifting of sanctions on four Indian companies on July 1, 2026, is telling. These companies had been sanctioned for providing financial assistance to the Russian government. Have they ceased these activities? Is the decision conditional? Have they made any commitments? The official response is silence. And for Ukraine, this silence amounts to a partial betrayal of a framework it had hoped to see strengthened, not weakened.

Kyiv monitors the SDN list more closely than Washington acknowledges. This reversal of roles says it all: Ukraine is the one suffering the direct consequences of every change. And that is precisely why its expertise deserves to be taken seriously by its allies.

When standards become negotiable, sanctions lose their bite

The effectiveness of sanctions rests on a simple mechanism: targeted actors calculate that the cost of sanctioned behavior exceeds the benefit. This calculation holds true as long as sanctions are predictable, transparent, and consistent. When they begin to be perceived as negotiable—removable through diplomatic channels, modifiable according to the needs of the moment—the calculation changes. Rational actors—whether Russian oligarchs, banks, or third-party facilitator companies—adapt their behavior accordingly: they avoid the most blatantly visible actions but continue their activities in the gray areas created by silent waivers.

This phenomenon is not unique to sanctions against Russia. It has been observed in sanctions against Iran, North Korea, and Venezuela. But in the case of Russia, the stakes are particularly high: every dollar of funding that Moscow loses or gains can translate into tangible military results on a front where every metric ton of ammunition counts. The silent erosion of sanctions, even if marginal, comes at a human cost. And that cost is borne, as always, by people who are not in the boardrooms where these decisions are made.

The G7’s Resilience in the Face of Divergent Pressures

The G7 sanctions regime against Russia has demonstrated remarkable resilience since 2022—despite Hungarian resistance in Europe, despite Trump’s ambivalence, and despite economic pressures on member states. This resilience is not a given: it must be negotiated, defended, and actively maintained with each new round of sanctions. The silent removals from the U.S. SDN list are testing this solidarity. They do not break it—but they erode it. And solidarity that is gradually eroded is, in the long run, just as fragile as non-existent solidarity.

France, Germany, the United Kingdom, and the other allies have a responsibility here: not to let the removals pass without at least questioning their justification. The allies’ silence in the face of U.S. removals from the SDN list is just as problematic as their silence in the face of Turkish repression in Ankara. In both cases, the message being sent is: we accept it. We are not asking for an explanation. And this message, repeated often enough, becomes an endorsement.

The G7 has built a remarkable sanctions regime against all odds. It would be a shame to let it erode through a series of silent removals. The robustness of a system is also measured by what it refuses to tolerate within its ranks.

Washington Caught Between New Delhi and Kyiv: An Impossible Balance

The lifting of sanctions on four Indian companies on July 1, 2026, highlights a structural dilemma in U.S. policy: how to maintain economic pressure on Russia while preserving the strategic partnership with India, a key player in the competition with China? India is the largest buyer of Russian oil after China. It refused to condemn Russia’s invasion of Ukraine at the United Nations. And it continues to maintain significant commercial and military ties with Moscow. In this context, sanctioning Indian companies for their support of the Russian government invariably creates diplomatic tensions that Washington does not want to manage indefinitely.

The lifting of these sanctions following “extensive dialogue” illustrates what diplomats call “sanctions fatigue” toward third parties. Sanctioning allied or partner countries for their trade with nations that are themselves under sanctions is politically and legally complex. These secondary sanctions exist in the U.S. arsenal—but they are used sparingly against strategic partners. And this restraint comes at a cost: it sends the signal that key third parties can afford to assist Russia without lasting consequences.

Diplomatic Pressure as a Substitute for Sanctions

The “sustained dialogue” between Washington and New Delhi mentioned in the Ukrainian reports is an implicit acknowledgment that sanctions were used as a negotiating tool rather than as a punitive measure. This is a well-known practice—sanctions as a step in a dialogue, not as an irrevocable verdict. It can yield results: if New Delhi made commitments to reduce its purchases of Russian oil or to cut ties with sanctioned Russian companies, the lifting of sanctions was justified. But no such commitments have been publicly announced. No conditions have been made transparent. And that is precisely the problem.

Ukraine observes this game with bitter clarity. It knows that Washington cannot afford to alienate New Delhi at a time when competition with China is the number one priority of U.S. foreign policy. It knows that its own interests take a back seat to this broader strategic calculation. And it says so—not out loud, not officially, but in its technical reports, in its calls for transparency, and in Vlasyuk’s vigilance.

Washington cannot please New Delhi and Kyiv at the same time. This dilemma is real, and I do not downplay it. But resolving it behind closed doors—without public explanation or transparent criteria—means choosing diplomatic convenience at the expense of democratic legitimacy. That choice comes at a price.

Mandatory Transparency as a Minimum Standard

I am not a policymaker. I am a columnist. But I have opinions, and I stand by them. Here is what I think should change in U.S. sanctions policy toward Russia. First: Any removal from the SDN list of an entity designated in connection with the war in Ukraine should be accompanied by a minimal public explanation. Not a novel—but a paragraph. What behavior has changed? What condition has been met? What assurance has been obtained? This transparency would not compromise national security. It would strengthen the credibility of the sanctions regime.

Second: diplomatically motivated removals—such as the lifting of sanctions on Indian companies in the context of the agreement with India—should be accompanied by verifiable commitments from the companies involved. If an Indian company has helped Russia circumvent sanctions, its reinstatement should be contingent on an audit of its practices, not on opaque diplomatic negotiations. This standard exists in other regulatory contexts—competition law, integrity agreements in public procurement. It can be applied to sanctions.

Ukraine as a Partner, Not a Passive Recipient

Perhaps the most important lesson from Ukraine’s handling of sanctions is this: Ukraine should be formally involved in decisions to amend the SDN list that directly affect it. Not as the final decision-maker—U.S. foreign policy remains a U.S. prerogative—but as a systematic consultant, whose advice is sought and documented. Vlasyuk’s office possesses expertise that U.S. agencies lack. It would be a strategic waste not to utilize it.

This formal involvement is not a pipe dream. It could take the form of a mechanism for prior consultation on changes to the SDN list related to the conflict in Ukraine—with a response deadline, a forum for bilateral discussion, and a requirement to provide justification in the event of disagreement. This mechanism would enhance both the quality of U.S. decisions and Kyiv’s trust in its ally. In a war that has lasted more than four years, that trust is worth something.

Ukraine deserves to be consulted before Washington removes names from a list that was created, in part, to protect it. It is a matter of respect—and in relations between allies, respect is also a form of strategy.

What Removing a Name Means in Practical Terms

When OFAC removes an entity from the SDN list, the immediate consequences are tangible. Frozen assets are released. The corresponding bank accounts become accessible again. U.S. companies and their subsidiaries can once again do business with the entity. Marine insurers can provide coverage for the affected vessels. In the case of prominent figures like Ivan Potanin, this means that financial transactions that were previously impossible are once again feasible. The exact amount of assets released is not public—but for executives at Norilsk Nickel and sanctioned banks, it is likely significant.

The network effect may be even more significant. In the world of sanctions, the SDN list carries symbolic weight far beyond the formal restrictions it imposes. Companies and financial institutions around the world use this list as a reference for their internal compliance policies—a practice known as “de-risking.” When an entity is removed from the list, these institutions reassess their own risk evaluations. Ivan Potanin’s removal from the SDN list could thus open doors at Swiss banks, London investment funds, or Asian stock exchanges that had adopted precautionary restrictions going beyond strict legal requirements.

Six Removals from the List: A 6% Erosion of the System

Each individual removal may seem minor. But when you add them up—in June 2026, dozens of names linked to the war in Ukraine were removed in successive waves—the cumulative effect becomes significant. The sanctions regime is a system: its effectiveness depends on its consistency and scope. If names are regularly removed without explanation or compensation, the pressure exerted on the Russian war economy is gradually reduced. These removals may seem insignificant when taken in isolation. Combined, they constitute a real erosion.

This is exactly what Ukrainian monitoring agencies are documenting: not the spectacular collapse of the sanctions regime, but its gradual, discreet, cumulative erosion. This erosion is the scenario Putin has always anticipated—not a sudden breakdown of Western solidarity, but a buildup of weariness that eventually renders the sanctions symbolic rather than biting. Every silent removal contributes to this scenario. And every silent removal deserves to be named.

Wear and tear is not a collapse. It’s worse: it’s a slow digestion of what should have remained intact. Putin has understood that democracies grow weary. Every name erased without explanation proves him a little more right.

The SDN List as a Barometer of Western Conviction

The SDN list is not merely an economic tool. It serves as a barometer of Western conviction regarding its own policy on Ukraine. Each entry represents a decision: we believe this entity contributes to Russian aggression, and we exclude it from our economic system. Each removal represents the opposite decision: we have changed our minds, or circumstances have changed, or something else has taken precedence. These decisions should be public, justified, and open to scrutiny. They are not. And as long as they remain so, the SDN list will remain what it is becoming: a flexible tool rather than a rigid framework.

In June and July 2026, while Ukrainian soldiers were dying on the front lines in the Zaporizhzhia and Kherson regions, OFAC was quietly removing names from its blacklist. There is no direct causal link between these two events. But there is a moral connection: sanctions are one of the tools democracies use to reduce Putin’s ability to wage this war. Weakening them without explanation—even marginally, even quietly—contributes to prolonging the war. And that contribution deserved to be called out.

What I take away from this column

I take away that the sanctions war is just as important as the war in the trenches—and that it is largely played out behind the scenes, far from the cameras, in the columns of the SDN list and the OFAC registries. I take away that Ukraine is, in this struggle, both the most vigilant player and the one least consulted. And I take away that transparency—that democratic minimum we demand of governments regarding even their most routine decisions—is all too often absent from the most extraordinary decisions, those concerning war and peace.

The names removed from the SDN list on June 24, 2026, may not make tomorrow’s headlines. But they deserved at least a column.

Washington’s silence regarding its own sanctions decisions is itself a political decision. And this decision, week after week, tells Kyiv: You matter, but not as much as other considerations. Ukraine deserves an ally who says otherwise.

Signed, Maxime Marquette, columnist