Refiling a Delisting Petition: How to Use Prior Denials
How Many Times You Can File a Delisting Petition
There is no formal cap on the number of delisting petitions a party may file with OFAC; neither 31 C.F.R. § 501.807, nor any other OFAC regulation limits the number of attempts. Refiling a delisting petition is, in that narrow sense, always available. In practice, however, this does not mean refiling is worthwhile on its own terms: the number...
Asset Unblocking After Delisting: Why There’s No Automatic Return
What Delisting Actually Changes, Legally
When the Office of Foreign Assets Control (OFAC) removes a person or entity from the SDN List, one specific thing happens: the entry is deleted from the sanctions list. As a legal matter, the individual or company is no longer a blocked person under U.S. sanctions law. But a delisting decision is not, by itself, an instruction to any bank to release a...
OFAC SDN Delisting: Lawsuit or Petition? Lessons from the Zadornov, Buriko, and Maltsev Cases
What Happened on June 11, 2026
On June 11, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) updated its Specially Designated Nationals and Blocked Persons List (SDN List). Two Russia-linked individuals were removed: Sergey Aleksandrovich Maltsev, a former deputy chairman of the management board of Sberbank, and Olga Borisovna Raykes, a businesswoman...
Constitutional Claims Against OFAC: Due Process, the First Amendment, and Ultra Vires
When a client challenges sanctions in a U.S. court, the workhorse is usually the Administrative Procedure Act (APA): the court asks whether the decision of the Office of Foreign Assets Control (OFAC) was arbitrary, unexplained, or procedurally defective. That tool has a ceiling. In matters touching national security and foreign affairs, courts give OFAC substantial deference, and an “arbitrary...
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...
Indian Companies Delisting: OFAC Removes Four Firms from the SDN List
What Happened on June 30, 2026
On June 30, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed four Indian companies from the Specially Designated Nationals and Blocked Persons List (SDN List) under the RUSSIA-EO14024 program. This Indian companies delisting covered RRG Engineering Technologies Private Limited and Lokesh Machines Limited (both based in...
New OFAC Reconsideration Portal: What Has Actually Changed
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...
OFAC Removes Turkish Sanctions Evasion Network from Russia-Related SDN List
What Happened on June 29, 2026
On June 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed seven entries from the Specially Designated Nationals and Blocked Persons List (SDN List) under the RUSSIA-EO14024 program. All seven are Turkish companies and individuals previously designated for supporting Russia's military-industrial base through sanctions...
OFAC GL 131G: New General License for Transactions Involving Lukoil International GmbH
Why OFAC Issued GL 131G
On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil as part of a broader campaign to degrade Russia’s energy revenues and its capacity to finance the war. At the same time, OFAC recognized the practical reality: Lukoil holds substantial assets outside of Russia, and an orderly divestiture of those assets to non-blocked buyers serves U.S....
Russia Sanctions Delisting: Who OFAC Removed from the SDN List on June 24, 2026
What Happened on June 24, 2026
On June 24, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published a routine update to the Specially Designated Nationals and Blocked Persons List (SDN List), removing seven individuals, two Russian-flagged cargo vessels, and two Turkish legal entities. All were designated under the RUSSIA-EO14024 sanctions program,...