OFAC Penalty for Sanctions Violations: What Actually Reduces the Amount
The Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) does not have to prove intent. Liability attaches to the act itself: the payment cleared, the goods shipped, the account was serviced. Intent affects how much a company pays, not whether it is liable at all.
Violations also rarely look like deliberate evasion. More often they come from an ownership stake...
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...
Changed Circumstances as Grounds for Removal from the SDN List
Among the individuals and entities named on the U.S. Treasury’s Specially Designated Nationals (SDN) List, maintained by the Office of Foreign Assets Control (OFAC), one question comes up more than any other: “My situation has changed, can I come off the list?” It is a fair question. A listing rarely reflects a person or company forever: businesses are sold, positions are vacated, controlling...
Civil Nuclear Energy Sanctions: OFAC General License 115D Explained
What Changed on June 11, 2026
On June 11, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 115D, “Authorizing Certain Transactions Related to Civil Nuclear Energy.” It replaced and superseded General License 115C, which had been in force since December 2025. The substance is unchanged, but the authorization now runs six months...
OFAC License Application Mistakes and How to Fix Them with an Amendment
OFAC’s Formal Requirements: Few Rules, But No Reason to Relax
The Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) does not impose rigid procedural requirements on the form of an OFAC specific license application. The regulatory framework, primarily 31 C.F.R. § 501.801, provides only general guidance: describe the nature of the request, identify the parties...
Challenging OFAC Sanctions in Court: The Albanese Case and the D.D.C. Preliminary Injunction
On May 13, 2026, the U.S. District Court for the District of Columbia (D.D.C.) issued a preliminary injunction in L.C. et al. v. Trump (L.C. v. Trump), suspending sanctions enforcement against Francesca Albanese, a United Nations Special Rapporteur on Human Rights. The case has become a landmark example of challenging OFAC sanctions in court: the court blocked enforcement of a decision by the...
Can You Obtain the OFAC Administrative Record Without Filing Suit?
Access to the case file, known in U.S. administrative practice as the administrative record, is one of the key questions in sanctions practice. The answer determines whether a designated party can build a focused legal position or must work blind, with only the agency’s general formulations to react to. The practical answer is short: the OFAC administrative record becomes available to a...
Lukoil Foreign Assets Sale: GL 131E Extends the Negotiation Window to May 30, 2026
What Happened on April 29, 2026
On April 29, 2026, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued General License No. 131E (GL 131E), extending the authorization for negotiations and the execution of conditional contracts for the sale of Lukoil International GmbH (LIG), the Austrian holding company through which Lukoil manages its foreign operations. The new...
Lawsuit Against OFAC: Why the District of Columbia Is the Forum
Lawsuit against OFAC: where these cases are heard
When a client is added to the SDN list and then denied delisting by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), or refused an OFAC specific license, the question eventually arises: can OFAC’s decision be challenged in court, and if so, where? A lawsuit against OFAC is available, and in the overwhelming...
Zadornov SDN Delisting: How It Was Done
On April 3, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) announced the Zadornov SDN delisting, ending nearly four years of U.S. blocking sanctions. The result followed a deliberate two-stage legal strategy: an administrative petition to OFAC, followed by a lawsuit in federal court. Below, we analyze how this was accomplished and what lessons the case...