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 US's 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. 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. This mechanism is central to OFAC's 2026 strategy against Hengli: the enforcement pressure falls on the dollar-clearing bank, not the commodity producer or its host government. The Rusal precedent is the upside case for OFAC enforcement on Hengli; the downside case is Iran's own 2018-2020 oil-sanctions cycle, where concerted state backing enabled workarounds through yuan and barter.

Rusal was subsequently restructured and relisted in 2019. Deripaska lost majority control, satisfying OFAC's requirements, and sanctions were lifted. The company is now publicly traded as En+ Group's primary asset. Its 2018 experience remains the clearest evidence base for how dollar-clearing sanctions transmit in practice.