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...
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...
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,...
Sakhalin-2 Sanctions: OFAC General License 55F 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. 55F, “Authorizing Certain Services Related to Sakhalin-2”. It replaced and superseded General License 55E, in force since December 2025. The authorization is unchanged in substance, but its term has been extended: transactions related to the...
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 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...