OFAC Asset Unblocking Denial: Next Steps and the Path to Court
An OFAC asset unblocking denial often feels like the end of the road. In practice, it rarely is. The Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) decides unblocking applications under broad administrative discretion, but its decision is neither beyond legal consequence nor beyond review. This article explains what a denial actually means, what administrative...