Meshkat Law represents individuals, entities, aircraft, and vessels seeking removal from OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) and other OFAC sanctions lists. We guide clients through the administrative reconsideration process, from initial assessment and petition strategy to engagement with OFAC and, where relevant, coordination with other U.S. agencies.
SDN designations typically occur with no prior notice, resulting in severe financial and reputational repercussions. SDN designations can block a person’s property and interests in property subject to U.S. jurisdiction and prohibit U.S. persons from dealing in virtually any activities with them. Identification on other, less-restrictive OFAC sanctions lists, such as the Sectoral Sanctions Identifications (SSI) List, can also substantially limit U.S. persons’ dealings with the designated party. In practice, SDN listings and other OFAC designations can also trigger so-called “secondary sanctions” risk, over-compliance, and reputational concerns that lead non-U.S. counterparties and financial institutions to avoid dealing with affected persons altogether.
However, designated persons can petition OFAC—and, for certain designations, the U.S. Department of State—for removal by invoking the regulatory procedures in 31 C.F.R. § 501.807. Grounds for removal include establishing that an insufficient basis exists for the designation or that the circumstances resulting in the designation no longer apply. OFAC will also take into account remedial steps on the designated person’s part, such as, but not limited to, corporate reorganization or the resignation of persons from positions in a sanctioned entity.
We help clients understand how OFAC is likely to view their designation, what potential grounds for reconsideration may exist, and what additional steps, if any—such as corporate or governance changes, compliance enhancements, or other remedial measures—can strengthen their petition for removal.
We assist individuals, entities, vessels, and aircraft identified on the SDN List or other OFAC sanctions lists at every stage of the delisting process. This includes assessing the basis for designation, identifying potential grounds for removal, and developing an overall strategy for administrative reconsideration.
We prepare and submit petitions for removal under 31 C.F.R. § 501.807, draft responses to OFAC follow-up questions and requests for additional information, and, where appropriate, help coordinate meetings or other engagement with OFAC. We also advise on remedial steps—such as ownership or management changes and sanctions compliance enhancements—that can address OFAC’s concerns and strengthen the record in support of delisting.
Where appropriate, we also pursue litigation against the U.S. government to challenge OFAC designations or agency delays, coordinating court strategy with ongoing administrative reconsideration efforts.
Attorney Kian Meshkat has successfully represented SDN-listed individuals and entities in efforts to secure their removal from the SDN List under a variety of OFAC sanctions programs.
Prior results do not guarantee a similar outcome.
Yes. Persons identified on any sanctions lists administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), including the SDN List, can petition the agency for removal from the corresponding list(s). OFAC’s regulations set out the procedures for delisting requests. In general, persons seeking rescission of their designation must demonstrate that an insufficient basis exists for the designation or that there has been a change in circumstances, such as remedial measures taken by the petitioner, that renders the designation no longer applicable. Each petition is unique, and OFAC’s review can be lengthy, but each year OFAC removes numerous individuals and entities from the SDN List.
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