Rusal

Rusal is Russia's largest aluminium producer and the closest structural precedent to the Hengli Petrochemical situation in Iran. In April 2018, OFAC designated Rusal under Executive Order 13662 for links to Oleg Deripaska, a Russian oligarch subject to the Countering America's Adversaries Through Sanctions Act. OFAC issued a wind-down period structurally similar to General Licence V; within weeks the dollar-clearing freeze collapsed Rusal's global trading book and forced a settlement that removed Deripaska's controlling stake. Global aluminium prices spiked approximately 35% in three weeks before the settlement was reached, and Glencore and other major counterparties unwound positions within days.

Rusal's 2018 designation established that OFAC secondary sanctions on a major commodity producer in a third-country jurisdiction can transmit through dollar-clearing faster than through physical trade flows, even when the host state objects. Rusal was subsequently restructured and relisted in 2019, with Deripaska losing majority control and sanctions lifted. The company now trades publicly as En+ Group's primary asset, and its 2018 experience remains the clearest evidence base for how dollar-clearing sanctions transmit in practice.