What evidence is most effective in challenging an OFAC designation?

The strongest evidence directly contradicts OFAC’s stated basis for designation. This includes corporate records proving no ownership links to sanctioned entities, financial audits demonstrating divestment from prohibited jurisdictions, witness declarations rebutting alleged conduct, and documentary proof of mistaken identity. OFAC’s evidentiary standard is classified information, so designated parties often must disprove allegations without seeing the full government file. Effective petitions anticipate likely intelligence sources and systematically address each designation criterion. Expert reports — particularly on corporate structures or regional business practices — and evidence of changed circumstances carry significant weight in reconsideration proceedings.