“Because many sanctions authorities authorize the imposition of sanctions on non-US persons – not ordinarily subject to US jurisdiction – for engaging in material transactions with an SDN, many non-US persons will now refuse to transact with Ly, irrespective of jurisdictional considerations,” said Brendan Hanifin, a Chicago-based partner at law firm Ropes & Gray. “Given the primacy of the U.S. dollar in international financial transactions, the practical effect of the SDN designation will be to cut off Ly’s access to most of the global financial system.”
