Can Argentine or Chilean nationals challenge OFAC designations if they have no direct connection to the United States?

Yes, foreign nationals can challenge OFAC designations regardless of U.S. ties. The administrative delisting process through OFAC’s Office of Foreign Assets Control is available to all designated persons. However, judicial review in U.S. federal courts requires establishing minimal constitutional standing, which non-U.S. persons can achieve by demonstrating blocked U.S.-nexus assets. Argentine and Chilean petitioners typically pursue administrative reconsideration first, submitting detailed evidentiary packages demonstrating changed circumstances or mistaken identity. The process generally takes 12–24 months, though complex cases involving national security considerations may extend significantly longer.