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OFAC Lawyers

The Office of Foreign Assets Control (OFAC) can designate individuals, companies, and assets with little warning — freezing funds and cutting access to the global financial system. Our OFAC lawyers challenge designations, pursue SDN list removals, and defend clients before U.S. Treasury.

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OFAC Lawyers — SDN List Removal and Designation Challenge

What Is OFAC Designation and Why It Matters

The U.S. Office of Foreign Assets Control (OFAC) is a division of the Department of the Treasury that administers and enforces economic sanctions programmes. An OFAC designation — also known as SDN (Specially Designated National) listing — blocks all U.S. persons from conducting transactions with the designated individual or entity and freezes all assets under U.S. jurisdiction.

The consequences of an OFAC designation are severe and far-reaching: bank accounts are frozen, international wire transfers blocked, business relationships severed, and correspondent banking access lost globally. Many foreign financial institutions apply de facto blocking even when not legally required, treating SDN status as a financial death sentence.

OFAC designations affect Russian businessmen, Ukrainian oligarchs, Middle Eastern companies, Latin American individuals, and any party connected to sanctioned programmes including Russia, Iran, Syria, North Korea, Venezuela, and Cuba. If you or your company appear on the SDN list, immediate legal action is critical.

Grounds for SDN Removal and Delisting

Mistaken identity: The designation targets the wrong person — a name match or clerical error by OFAC.
Factual inaccuracy: The underlying basis for designation is factually incorrect or relies on outdated information.
Changed circumstances: The conditions that led to designation no longer exist — e.g., the person has divested from sanctioned entities or countries.
Legal challenge: The designation violates due process rights, exceeds statutory authority, or fails to meet the required evidentiary standard.
Licensing: Even if designation stands, specific licences can be obtained from OFAC to permit otherwise prohibited transactions.
Settlement and compliance: Voluntary disclosure of historic violations and a compliance programme may support delisting or civil penalty reduction.

Our OFAC Legal Process

Our OFAC lawyers begin with a full assessment of the designation — reviewing the Federal Register notice, identifying the stated legal basis, and evaluating available grounds for administrative reconsideration under 31 C.F.R. § 501.807. We prepare a comprehensive administrative petition to OFAC’s Office of Global Targeting, supported by evidence and legal memoranda.

In parallel, we assess the viability of judicial review in the U.S. courts under the Administrative Procedure Act, and where applicable, advise on related EU, UK, or UN sanctions designations that may have been triggered by the OFAC listing. Many of our clients face simultaneous OFAC, EU, and UK sanctions — requiring a coordinated multi-jurisdictional strategy.

We serve clients from Russia, the UAE, Ukraine, Turkey, and Latin America facing OFAC designations under the Russia/Ukraine, Global Magnitsky, and Counter Narcotics programmes. Contact us at +357 96 447475 for an urgent assessment.