Ofac Lawyers

OFAC has no statutory deadline for responding to administrative reconsideration requests. In practice, responses range from 6 months to over 3 years, depending on the sanctions programme, the complexity of the case, and geopolitical factors. Russia-related designations currently experience the longest delays due to volume and policy considerations. OFAC may request additional information during review, […]

Delisting removes the legal obligation for U.S. persons and institutions to block your assets, but foreign banks often maintain their own risk policies. Many international banks — particularly those with U.S. correspondent relationships — conduct independent due diligence and may require additional documentation before restoring services. Some institutions impose extended monitoring periods or decline to […]

Yes. OFAC issues specific licences authorising otherwise prohibited transactions with SDN-listed parties under 31 C.F.R. Part 501. Common grounds include payment of legal fees, humanitarian transactions, wind-down of pre-existing contracts, and family maintenance. Licence applications must detail the transaction, parties involved, and justification. Processing times vary from weeks to several months. Licences are discretionary — […]

No. OFAC, EU, and UK sanctions are legally independent regimes. However, significant overlap exists in practice — particularly under coordinated programmes targeting Russia, Belarus, and human rights violators. EU and UK authorities monitor OFAC designations and may impose parallel listings based on shared intelligence or policy alignment. The legal criteria differ: EU sanctions require Council […]

The strongest evidence directly contradicts OFAC’s stated basis for designation. This includes corporate records proving no ownership links to sanctioned entities, financial audits demonstrating divestment from prohibited jurisdictions, witness declarations rebutting alleged conduct, and documentary proof of mistaken identity. OFAC’s evidentiary standard is classified information, so designated parties often must disprove allegations without seeing the […]

Yes. OFAC operates under an ex parte system, meaning designations are imposed without advance notice or opportunity to respond. The Treasury Department justifies this approach on national security grounds — providing warning would allow targets to move assets before freezing. Designated parties only learn of their status when it appears in the Federal Register or […]