The Treasury Department’s Office of Foreign Asset Control (OFAC) rarely backs down.  Recently, in response to significant ownership and governance changes, OFAC removed three Russian companies, EN+ Group (EN+), UC Rusal plc (Rusal), and JSC EuroSibEnergo (ESE) from the sectoral sanctions list. (Here). OFAC’s decision to remove the three companies capped the efforts of Russian oligarch, Oleg Daripaska, to modify his ownership and control of...