family-based-sanctions 17 July 2025

Family-based sanctions legal under IEEPA, says US court 

A federal judge has ruled that US authorities can legally sanction adult children of designated individuals under emergency powers legislation, rejecting a challenge from the family of sanctioned Cypriot businessman Christodoulos Vassiliades in a decision that clarifies the scope of presidential emergency authorities.

The DC District Court found Thursday that the International Emergency Economic Powers Act provides broad authority to impose sanctions that deal with declared threats, even when targeting individuals who have not directly contributed to the underlying emergency.

Anna Maria and Giorgos Vassiliades, adult children of the businessman, had challenged their 2023 designations under Russia sanctions, arguing that IEEPA requires sanctions to target only those who pose threats themselves.

‘IEEPA does not limit the President to sanctioning only those who have “contributed to a threat”,’ Judge Timothy Kelly wrote in the 27-page decision, emphasising that Congress imposed only the requirement that sanctions serve ‘the purpose of acting against a threat’.

The case represents a significant test of the legal boundaries of family-based sanctions, which have become increasingly common tools in US economic pressure campaigns against adversarial regimes and their supporters.

Christodoulos Vassiliades was designated in April 2023 as a ‘prolific enabler of a number of Russian Oligarchs’ who served in leadership roles within Russian government entities. His children were subsequently sanctioned – Anna Maria for her role as a director in a blocked entity, and Giorgos as an ‘adult child’ of a designated person.

The siblings argued that sanctioning family members without individual culpability exceeded statutory authority and violated due process principles, describing their designations as punishment for ‘the sins of their father’.

The government defended family-based sanctions as serving legitimate policy objectives, arguing they ‘minimize the risk of asset flight’ and serve as ‘an additional deterrent to those considering engaging in sanctionable conduct’.

Judge Kelly explicitly rejected the plaintiffs’ argument that IEEPA requires ‘individualized determination’ of threat contribution, noting that ‘Congress chose a less restrictive limit’ than the precision sought by the family.

The decision provides important precedent for sanctions enforcement, clarifying that family-based designations need not demonstrate individual culpability as long as they serve the broader purpose of addressing declared national security threats.

https://www.courtlistener.com/opinion/10626860/vassiliades-v-blinken