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

There is no single standard across all sanctions regimes. In the EU, where a designated person disputes the reasons for listing, the Council must support those reasons with a sufficiently solid factual basis. In the UK, sanctions legislation generally permits designation where the minister has reasonable grounds to suspect that a person is involved in specified conduct and considers the designation appropriate.

In the United States, OFAC’s evidentiary requirements depend on the statute, executive order, sanctions program, and specific designation criteria applicable to the case. A challenge may succeed where the underlying record relies on outdated, unreliable, or misattributed information, or fails to establish the required connection to sanctionable conduct.