How long does a sanctions delisting challenge typically take?

By Dr. Anatoliy Yarovyi — Senior Partner

Updated: 26 Oct 2026

The timeline depends on the sanctions regime, procedure, and complexity of the case. OFAC does not set a fixed deadline, and administrative reconsideration may take several months or longer. EU court proceedings can last more than a year, while UK review times vary by case. UN Ombudsperson delisting proceedings also usually take many months.

Sanctions usually remain in force while the challenge is pending. However, licences, exemptions, or interim relief may be available in certain circumstances.