Can I challenge an OFAC designation if the underlying evidence is classified or not disclosed to me?

Yes, but the process is challenging. OFAC frequently relies on classified intelligence that is not shared with designated persons. Your petition must anticipate and rebut the likely evidentiary basis using publicly available information, corporate records, and sworn declarations. In some cases, counsel can request that OFAC conduct an internal review of classified materials against exculpatory evidence you provide. US courts have ruled in cases like Holy Land Foundation that due process concerns exist, but judicial review of OFAC decisions remains highly deferential. Building a comprehensive administrative record is critical because litigation options are limited.