“Because many sanctions authorities authorize the imposition of sanctions on non-U.S. persons—who are not normally subject to U.S. jurisdiction—for engaging in material transactions with an SDN, many non-U.S. persons will now refuse to transact with Ly regardless of jurisdictional considerations,” said Brendan Hanifin, a Chicago partner at the 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 much of the global financial system.”