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, which resets informal timelines. There is no mechanism to compel a faster response administratively, though filing for judicial review under the Administrative Procedure Act can sometimes accelerate agency action by forcing OFAC to defend its position in court.
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