OFAC Delisting Denial: How Courts Review Agency Decisions Under the APA
From Denial to Federal Court: The Legal Path
When the Office of Foreign Assets Control (OFAC) denies a petition for removal from the SDN List, the denial is often issued with minimal explanation. For the designated party, this can feel like a final verdict. It is not. An OFAC delisting denial is an administrative decision, and like most administrative decisions, it is subject to review in...