Meshkat Law advises clients worldwide on U.S. economic sanctions programs administered by the Office of Foreign Assets Control (OFAC), focusing on complex matters where sanctions risks and cross-border business collide. The firm provides counseling and representation in high-stakes OFAC compliance, licensing, enforcement, and list-removal matters.
OFAC administers and enforces U.S. economic and trade sanctions, targeting certain countries, regions, sectors, and designated individuals and entities in response to national security and foreign policy concerns. Its regulations can prohibit or restrict a wide range of dealings with sanctioned jurisdictions and parties.
Through country-based programs (such as those related to Iran, Russia, Cuba, Venezuela, North Korea, and others) and list-based programs, including the Specially Designated Nationals and Blocked Persons (SDN) List and other sanctions lists, OFAC can effectively cut targets off from the U.S. financial system and many cross-border transactions. For businesses and individuals, that can mean blocked funds, counterparties refusing to perform, and material civil or, in some cases, criminal exposure if sanctions rules are violated.
Our OFAC Sanctions Practice is built to help clients navigate this landscape across the full lifecycle of sanctions risk. We advise on day-to-day OFAC compliance, pursue specific licenses and unblocking requests, represent clients in OFAC administrative subpoenas and enforcement actions, seek removal from OFAC sanctions lists, and advocate before the agency to resolve sensitive matters. We also regularly advise on matters where OFAC sanctions issues intersect with BIS export controls, and are sensitive to the practical and legal nuances that arise when both regimes are in play.
We provide clients with routine transactional advice, including drafting legal advisory opinions and due diligence support, for issues invoking OFAC sanctions programs. We also assist client organizations in the design and administration of their OFAC sanctions compliance programs, including risk assessments, training, audits, internal investigations, and OFAC sanctions list-screening support.
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We assist clients with OFAC licensing matters, including applications for specific licenses, unblocking requests, and interpretive guidance from OFAC’s Licensing Division. Drawing on Kian Meshkat’s experience obtaining OFAC licenses for a wide range of clients, we help frame complex fact patterns, prepare supporting documentation, and work to secure licenses that allow lawful completion, restructuring, exiting affected transactions, and the unblocking of blocked assets or funds.
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We represent clients seeking removal from OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List and other OFAC sanctions lists (e.g., SSI List). Drawing on years of experience successfully obtaining delistings and other tailored relief from the U.S. government, we assess listing rationales, develop factual and legal arguments for reconsideration, coordinate remedial steps, and prepare detailed submissions to OFAC to support delisting.
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We represent clients facing OFAC administrative subpoenas, enforcement inquiries, and potential civil penalty actions. Our work includes assessing potential violations, managing internal fact‑finding, preparing responses and voluntary self‑disclosures, and negotiating with OFAC to resolve investigations in a way that addresses regulatory expectations while protecting our clients’ business and reputational interests.
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We assist clients with strategic advocacy before OFAC outside the enforcement and licensing context, including pre-designation engagement, interpretive questions, and other policy-sensitive matters.
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