Can I challenge a sanctions designation if I was never notified before being listed?

Yes, lack of prior notification does not preclude a challenge and may strengthen it. Many sanctions regimes, particularly OFAC and EU measures, permit designation without advance notice based on concerns about asset flight. However, the European Court of Justice has repeatedly held that inadequate disclosure of reasons or evidence supporting designation violates fundamental rights of defence. A challenge can argue that the designating authority failed to provide a sufficient statement of reasons, that the evidence relied upon was never disclosed, or that the designation was based on outdated or inaccurate intelligence. These procedural deficiencies can form independent grounds for annulment.