Getting Off the SDN List: A Practical Guide to OFAC’s Administrative Reconsideration Process
Landing on the Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List) is one of the most consequential things that can happen to a company or individual doing business in or with the United States. Assets are frozen, U.S. persons are barred from dealing with you, and banking relationships evaporate almost overnight.
The good news is that SDN designations are not necessarily permanent. OFAC maintains a formal process – administrative reconsideration – for petitioning to have a person, entity, or piece of property removed from an OFAC-administered sanctions list. This article walks through how that process works, what to expect at each stage, and where clients most often stumble.
Step One: Confirm You’re Using the Right Process
Before filing anything, it’s worth pausing to confirm which removal process actually applies to your situation, because OFAC’s administrative reconsideration process is not a one-size-fits-all remedy.
- You are the designated party. If you, your organization, or your property appear on an OFAC-administered list because OFAC itself made the designation, the administrative reconsideration process under 31 C.F.R. § 501.807 is the correct path, and it runs through OFAC’s Reconsideration Portal.
- The designation was made by the State Department. Some names appear on OFAC-administered lists because the Department of State designated them (for example, under certain terrorism-related authorities). Removal in those cases goes through […]
