What standard of proof must the sanctioning authority meet to maintain my designation?

The standard varies by regime but is generally lower than criminal proof. OFAC requires only ‘reason to believe’ based on credible evidence, while EU courts apply a ‘sufficiently solid factual basis’ test established in cases like Kadi II. The UK applies a ‘reasonable grounds to suspect’ threshold under the Sanctions and Anti-Money Laundering Act 2018. Crucially, the burden lies with the designating authority to justify the listing — not with the designated person to prove innocence. Successful challenges often demonstrate that underlying intelligence is stale, misattributed, or fails to establish the required nexus to sanctionable conduct.