OFAC Lawyers

OFAC — the Office of Foreign Assets Control — is a financial intelligence and enforcement agency of the U.S. Department of the Treasury. It administers and enforces economic and trade sanctions against targeted foreign countries, governments, entities, and individuals deemed a threat to U.S. national security, foreign policy, or the economy. OFAC maintains the Specially Designated Nationals (SDN) list, which effectively blacklists designated persons from the U.S. financial system and, in practice, from the broader international financial infrastructure. Being placed on the SDN list results in the immediate blocking of all U.S.-held assets and a prohibition on U.S. persons — including banks and corporations worldwide — from engaging in transactions with the designated party. The consequences extend far beyond the United States: most global financial institutions apply OFAC compliance standards, making an SDN designation a de facto global economic exclusion.

OFAC designations can target a wide range of parties. Individuals — including businesspeople, politicians, and family members of designated persons — may find their assets frozen and their ability to conduct international business or travel severely restricted. Companies and corporate structures, even those with only indirect connections to a designated individual, can be caught under OFAC’s “50 percent rule,” which extends designation to entities owned 50% or more by an SDN. Assets — including bank accounts, real estate, vessels, aircraft, and securities — are blocked the moment a designation takes effect. The impact is immediate and often devastating: bank accounts are frozen without notice, contracts are voided, and reputational damage follows quickly. Our clients include business owners wrongly caught in sanctions sweeps, family members designated by association, and companies seeking to restructure their ownership to comply with OFAC requirements.

Our OFAC lawyers pursue every available legal avenue to challenge designations and secure removal from the SDN list. The primary route is an administrative petition for reconsideration submitted directly to OFAC, presenting legal arguments and factual evidence demonstrating that the designation criteria are not met or that the evidentiary basis is flawed. We prepare comprehensive submissions addressing the specific legal grounds for designation — whether under Executive Orders, the Global Magnitsky Act, or sectoral sanctions programmes — and request access to non-classified evidence where possible. Where administrative reconsideration is insufficient, we pursue judicial review before U.S. federal courts, challenging OFAC’s decision-making process for procedural and substantive defects. In parallel, we advise on OFAC licensing — obtaining specific or general licences to authorise transactions that would otherwise be prohibited — enabling clients to maintain essential business operations while the challenge proceeds. We also coordinate with international sanctions counsel to pursue simultaneous delisting from EU, UK, and UN sanctions lists, ensuring a consolidated global approach to each client’s situation.

We approach each OFAC matter as a multi-track legal challenge. From the moment of instruction, we analyse the designation notice in full, identify the underlying Executive Order or statutory authority, and map the factual and legal vulnerabilities in OFAC’s case. We advise on asset protection measures within the bounds of applicable law, engage specialist U.S. co-counsel where required, and build the evidentiary record that forms the backbone of both administrative and judicial proceedings. Our team has experience representing clients across industries — including commodities, banking, real estate, and technology — who have been designated under programmes targeting Russia, Iran, Venezuela, Belarus, and other jurisdictions. We work with former government officials, forensic accountants, and compliance specialists to construct the strongest possible challenge. For newly designated clients, we act immediately to mitigate operational disruption, communicate with relevant financial institutions, and file urgent licensing requests where time is critical.

If you or your company has been designated by OFAC or placed on the SDN list, time is critical. Our international sanctions and OFAC lawyers are available for an immediate confidential consultation. We advise clients worldwide and coordinate across U.S., EU, and UK legal jurisdictions to pursue the fastest possible path to delisting. Contact us today to discuss your options.

A common misconception is that OFAC sanctions only affect US citizens and companies. In reality, OFAC’s reach extends far beyond US borders through what regulators call the “50% rule” and correspondent banking relationships. Non-US persons face material risk in the following circumstances:

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• US dollar transactions: Any payment processed in USD — even between two non-US parties — passes through a US correspondent bank and is subject to OFAC screening. An SDN-listed individual can be blocked from conducting dollar transactions globally.
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• Non-US subsidiaries of US entities: Foreign subsidiaries of US companies are generally bound by the same OFAC restrictions as their US parent.
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• Secondary sanctions: Certain OFAC programmes (Iran, Russia, North Korea, Venezuela) impose secondary sanctions on non-US persons who engage in significant transactions with primary targets. EU, UK, and UAE nationals have faced OFAC secondary sanctions exposure.
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• SDN list as reputational trigger: Even where no direct enforcement action is taken, an OFAC listing causes European and GCC banks to close accounts, freeze assets, and terminate business relationships under their own compliance policies.
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Our OFAC lawyers advise clients from the UAE, Turkey, Russia, Ukraine, and throughout the EU on managing and removing this exposure. The earlier you engage specialist counsel, the more options are available.

An increasing number of clients face simultaneous exposure to both OFAC sanctions listings and Interpol Red Notices — sometimes filed by the same country’s authorities. This dual exposure creates a particularly dangerous situation:

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• OFAC designation is cited in the Interpol Red Notice, lending it apparent credibility;
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• The Interpol Red Notice is used by foreign prosecutors to justify the OFAC request;
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• Banks, immigration authorities, and Visa issuers react to both simultaneously, creating a web of restrictions that is difficult to untangle piecemeal.
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Effective defence requires a coordinated strategy addressing both instruments in parallel. Our team includes specialists in Interpol Red Notice removal before the CCF and OFAC delisting proceedings before the Office of Foreign Assets Control. We map the exact interdependency between the two designations and develop a sequenced strategy that maximises the probability of full clearance.

This is particularly relevant for Russian and Ukrainian nationals who may face US-origin OFAC listings alongside Russian or Ukrainian Interpol Red Notices. Call +357 96 447475 for a confidential strategy session.

OFAC delisting is formal process administered by OFAC’s Compliance team within the US Treasury. There are two main pathways:

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• Administrative reconsideration: A formal petition to OFAC arguing that the designation is factually incorrect, legally improper, or no longer warranted. OFAC reviews the record and may delist, modify, or maintain the designation. This process typically takes 12–24 months.
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• Licensing: In some cases, OFAC will issue a specific or general licence authorising certain transactions while the designation remains in place. This provides interim relief for banking and business activity while the reconsideration is pending.
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Successful delisting petitions are evidence-dense and legally technical. They must demonstrate that the factual premises of the designation are wrong, that the legal standard under the relevant Executive Order was not met, or that circumstances have materially changed. Our lawyers have prepared multiple successful OFAC submissions on behalf of UAE, Turkish, Russian, and European clients.