Can You Speed Up an OFAC Delisting Decision?
No Fixed Deadline for an OFAC Delisting Decision
A delisting petition is filed under 31 C.F.R. § 501.807. The petitioner must show either that there was no sufficient basis for the designation in the first place, or that the circumstances giving rise to it no longer exist. A petitioner can also propose specific remedial measures to address the reasons for the listing, such as a change in...
OFAC Delisting Petition Documents: What Works and What Gets Ignored
What Is an OFAC Delisting Petition and Who Reviews It
The Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) maintains the Specially Designated Nationals and Blocked Persons List (SDN List) - a roster of individuals and entities whose U.S.-based assets are frozen and with whom American persons are broadly prohibited from doing business. Designation carries severe...
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...
Lukoil Sanctions: OFAC Issues GL 131D, Extending the Sale Window for Lukoil International GmbH Through May 1, 2026
On March 30, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) issued General License No. 131D (GL 131D), replacing GL 131C, which was set to expire on April 1, 2026. The new license extends through May 1, 2026, the authorization to negotiate and enter into contingent contracts for the sale of Lukoil International GmbH (“LIG”), the Austrian holding...
OFAC Request for Additional Information: What Does It Mean?
Introduction
A request from the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury for additional information or supporting documents is a fairly common occurrence when dealing with this agency. Such requests often arise, for example, when submitting an application to OFAC for a license or removal from the U.S. sanctions list.
There are also situations where...
What are the chances of being removed from the OFAC SDN List?
Introduction
Once you or your company have been added to the OFAC SDN List, a number of pressing questions inevitably arise: Is there anything that can be done? And if so, what exactly? Or would it be better to simply do nothing for the time being? Choosing to take no action is rarely a rational or defensible position when a person or entity is listed under U.S. sanctions. Here's why.
What...
When You Need to Apply for an OFAC License?
Introduction
An OFAC license may be either a General License or a Specific License. General Licenses are issued by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury on its initiative, as part of its mandate to implement and enforce U.S. sanctions policy.
This article focuses on OFAC Specific Licenses. Any individual or legal entity may apply for an OFAC...
What Should You Do If You’re Added to the OFAC SDN list?
Once you or your company have been added to the OFAC SDN list, inevitable questions arise: “Is there anything that can be done about this? And if so, what exactly? Or perhaps it’s better to wait and do nothing for now? ”Adopting a 'wait and see' approach is rarely a rational or justifiable response when an individual or business is placed on a U.S. sanctions list—and here’s why.
What Happens...