We prepare OFAC administrative reconsideration petitions to remove individuals and entities from the SDN list. Comprehensive legal submissions. International experience.
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Removal from the OFAC Specially Designated Nationals list — known as delisting — is the primary goal for anyone designated under a US sanctions programme. While the SDN list is administered by a US government agency, the legal and evidentiary work required to achieve delisting is substantial and demands specialist counsel with knowledge of both US sanctions law and the international context of each specific case.
There are two principal routes to SDN list removal:
Administrative reconsideration petitions must demonstrate one or more of the following: that the factual basis for the designation is incorrect; that circumstances have changed materially since the designation; that the designation is legally defective; or that removal would serve the interests of US foreign policy and national security. The burden is on the petitioner to establish these grounds with evidence.
A successful OFAC petition is a detailed legal and factual submission. It typically includes:
OFAC administrative reconsideration can take months or longer. During this period, the designation remains in effect. We advise on all available interim measures, including specific licence applications for essential transactions, exemptions for legal fee payments, and humanitarian derogations for necessary living expenses. These measures do not remove the designation but can allow limited, authorised activity while the petition is reviewed.
OFAC does not publish fixed timelines for reconsideration decisions. In practice, the process typically takes between six and eighteen months from submission. Complex cases involving multiple sanctions programmes or significant evidentiary disputes may take longer. OFAC may request additional information during the review, which extends the timeline.
SDN removal — delisting — means the designation is revoked and the individual or entity is no longer subject to OFAC sanctions. This restores full access to the US financial system. OFAC licensing is an authorisation for specific, limited transactions despite the designation remaining in place. A licence does not remove the designation — it permits certain described activities that would otherwise be prohibited. Both routes may be pursued simultaneously depending on the urgency and circumstances of the case.
Yes. OFAC can re-designate an individual or entity if new information comes to light or if circumstances change after removal. Individuals who have been delisted should be careful to maintain compliance with applicable sanctions programmes and avoid conduct that could provide a basis for re-designation. We advise clients on post-delisting compliance requirements.
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