What OFAC Launched on June 29, 2026

On June 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) launched a new online tool for submitting requests to be removed from its sanctions lists: the OFAC Reconsideration Portal. The portal replaces the previous practice under which petitioners submitted delisting petitions by email and then went through repeated rounds of follow-up questions from OFAC in separate correspondence. The new form front-loads the information OFAC needs, which is intended to reduce the number of question-and-answer cycles and speed up adjudication.

Through the same portal, petitioners can now also request a so-called courtesy document: unclassified, non-privileged information underlying their sanctions determination.

OFAC also signaled that it intends to move away from accepting petitions by email in the future, meaning the shift to the portal is likely to become mandatory rather than optional within a relatively short time.

It is worth noting that the portal’s architecture itself – a structured intake form covering the petitioner and the relevant circumstances first, followed by a free-form section for supporting documents and arguments – closely mirrors the design already in use on OFAC’s long-standing License Application Portal. As early as 2025, while the portal was still at the public-comment stage, professional press observed that since OFAC already had a functioning intake mechanism for license applications, a new portal for delisting petitions would likely be built on that same model.

Based on the final rollout, that is essentially what happened. This suggests that the launch is not an isolated fix aimed at a single process, but part of a broader OFAC effort to standardize the structure of submission and processing across its various petition and application types, regardless of whether the filing concerns a license or removal from a list.

Updated FAQ 897 and New FAQ 1261

Alongside the portal, OFAC updated Frequently Asked Question (FAQ) 897, which addresses how to seek removal from a sanctions list, and added new FAQ 1261, addressing what happens if a petition is denied. Under the new guidance, a denial does not close the matter permanently: a petitioner may be refiled, but only where new arguments or evidence are presented that were not previously submitted to OFAC. Refiling without new substantive material is likely to be denied based on the prior determination.

Two Grounds for Delisting

Substantively, the portal does not introduce new grounds for removal. OFAC continues to evaluate petitions under two established legal theories. The first is “changed circumstances”: the petitioner demonstrates that the conduct or conditions underlying the original designation no longer exist. The second is “insufficient basis”: the petitioner challenges the validity of the original designation itself, arguing it was unwarranted from the outset.

One practical change is worth noting: the OFAC Reconsideration Portal now formally allows a petitioner to raise both grounds simultaneously within a single petition.

The Courtesy Document

The ability to request the material underlying an original designation already existed, but in a considerably less formalized form. It is now requested through the same portal used for the petition itself, as part of a single process. This matters in practice: without understanding the factual basis for the original determination, it is difficult to build a persuasive argument under either delisting theory.

However, this approach generally does not yield the materials necessary to develop a complete picture of the case and formulate compelling arguments in support of delisting. OFAC is under no obligation to disclose the complete case file. Moreover, citing national security interests and applicable confidentiality restrictions, OFAC often redacts or withholds significant portions even of the limited documents it does produce.

What to Prepare Before Filing

The guidance materials published alongside the OFAC Reconsideration Portal – quick-reference guides on best practices and on what a petition should include – set out the required information depending on the petitioner’s status: individual, entity, or authorized representative. Among OFAC’s recommendations: do not combine different types of requests (for example, a delisting petition and a Freedom of Information Act request) in a single submission, respond promptly to any follow-up questions from OFAC, and provide an alternate email address for correspondence.

The Portal Changes the Form, Not the Substance

This distinction matters. The OFAC Reconsideration Portal changes how a petition is filed, not what it must show. The evidentiary standard (what must be proven under each theory, how much documentation is required, how the argument must be constructed) remains the same. A convenient online form does not compensate for a substantively weak petition; it will be denied just as it would have been by email.

If anything, a simplified filing process creates a risk of false confidence that the matter can be handled without counsel. In practice, the substantive work – selecting the right legal theory, assembling evidence of changed circumstances or insufficient basis, and managing the ensuing correspondence with OFAC – requires the same level of professional preparation as before the portal existed.

When the Administrative Path Fails: The Judicial Alternative

Where the administrative route does not produce results (a petition is denied, including on refiling under the new FAQ 1261, or it sits without action for years), a judicial alternative remains available. A lawsuit under the Administrative Procedure Act (APA), filed in the U.S. District Court for the District of Columbia (D.D.C.), can challenge a delisting denial or, in many cases not less important, seek a determination that OFAC’s delay in acting on the petition is unreasonable.

Practice shows that filing such a suit is often not the endpoint of the dispute but a source of leverage: once OFAC is on formal notice of litigation, it frequently moves toward settlement rather than allowing the case to reach a final judgment.

Practical Takeaways

The launch of the OFAC Reconsideration Portal is a meaningful step toward a more transparent and predictable process, not a change in what a petition must ultimately establish. For individuals and entities considering delisting, the practical takeaway is straightforward: it is worth using the new portal now, particularly given OFAC’s stated intention to move away from email. The substantive preparation, however (legal theory, evidentiary record, and handling of the document) demands the same professional rigor as it always has. And where the administrative path does not succeed, the judicial route remains available and, as experience shows, an effective source of leverage over OFAC.