OFAC Attorney Washington D.C. | Defense & Compliance
A pharmaceutical distributor in Maryland received a Treasury subpoena in February 2026 requesting transaction records dating back three years. The company had processed payments through an intermediary bank linked to an SDN-listed entity—exposure that could trigger penalties exceeding $2.4 million per transaction under the International Emergency Economic Powers Act. Legal counsel had 30 days to respond. Miss that window, and the Office of Foreign Assets Control opens a formal enforcement investigation, which typically adds 6–12 months of uncertainty and doubles the final penalty range.
FOur Washington DC team handles license applications, SDN delisting petitions, and sanctions enforcement defense directly with Treasury.
What Triggers OFAC Penalties
OFAC enforces 38 sanctions programs (Iran, North Korea, Syria, Venezuela, Russia, Cuba, Burma) plus 15 thematic programs covering terrorism, narcotics, and cyber threats. Violations fall into three tiers:
- Egregious — willful violations, falsified licenses, shell-company evasion. Civil penalties up to $356,579 per violation or twice the transaction value; criminal penalties up to $1M and 20 years under 50 U.S.C. § 1705.
- Non-egregious — negligence or isolated compliance gaps. Base penalties: $19,823–$178,289 per transaction.
- Cautionary letters — minor, first-time, or non-obvious violations. No penalty, but they raise your risk tier for future cases.
Between 2023–2025, OFAC assessed $1.48 billion across 94 actions. Companies that self-disclosed faced a median penalty of $387,000; those caught by third parties or investigation averaged $3.2 million.
As an SDN list compliance attorney, our team builds documented screening rationale under 31 CFR § 501.603(b)(1)(iii) to prevent false-positive matches from becoming strict-liability exposure.
Who Ends Up on the SDN List — Common Scenarios
Designation doesn’t always mean deliberate wrongdoing. Four recurring patterns bring clients to an OFAC delisting lawyer:
- Mistaken identity — a common name (transliterated Arabic, Cyrillic, or Farsi names especially) matches an SDN entry belonging to someone else entirely.
- Family or business association — a relative, business partner, or former employer gets designated, and the connection alone triggers a bank’s screening flag.
- Ownership-chain exposure — the “50% Rule” aggregates ownership stakes; an entity 50%+ owned (directly or indirectly) by a blocked person is itself blocked, even without independent wrongdoing.
- Country/sector designation — operating in a targeted sector (e.g., Russian energy, defense) or jurisdiction pulls otherwise uninvolved parties into scope.
Each scenario requires a different evidentiary strategy — mistaken identity relies on biometric and documentary proof of non-identity; ownership-chain cases require divestiture evidence and corporate records.
OFAC Attorney Washington D.C. | Defense & Compliance
Our team specialises in cases with an international element. We review applicable treaties, assess risks, and prepare an action plan.
Contact a lawyer →OFAC Licenses Attorney: General vs. Specific Licenses
OFAC issues two license types. General licenses authorize entire transaction categories without application — compliance with published terms is enough. Specific licenses require individual approval for everything else. As of 2026, OFAC maintains 287 active general licenses.
Examples of program-specific rules our OFAC licenses attorneys navigate:
- Iran — General License D-2 covers agricultural/medical goods but excludes EAR-controlled items and payments over $500,000 without notice.
- Russia — GL 8A permits wind-down transactions with VTB/Sberbank only for pre-March 2022 contracts.
- Venezuela — GL 41 allows humanitarian transactions with PdVSA/Banco de Venezuela, with mandatory 10-day Treasury notification.
- Cuba — Authorized travel requires 5-year recordkeeping to prove no dealings with the Cuba Restricted List.
A specific license application needs: legal justification tied to U.S. policy interest, full transaction and party details, counterparty due diligence, and an explanation of why no other structure works. Straightforward requests average 45 days; complex cases (blocked governments, deals over $10M) take 90–180 days. Roughly two-thirds of applications are approved.
When general and specific licenses don’t apply, an OFAC unblocking application attorney files a separate unblocking request — used when funds were frozen in error (no actual SDN match, an expired designation, or a transaction that never touched a blocked party). Unblocking requests require proof the freeze was mistaken rather than a request for permission to proceed, which is a materially different legal standard from a specific license.
SDN List Removal Lawyer: Delisting Standards and Process
Removal from the SDN List requires proving either the designation was legally flawed or no longer fits current policy. Between 2023–2025, OFAC processed 1,847 delisting petitions — full removal succeeded in 22.3% of cases, partial unblocking in another 16%.
As SDN list removal attorneys, we build petitions around four grounds:
- Changed circumstances — designated party severed ties to the sanctioned conduct;
- Mistaken identity — wrong name or faulty intelligence;
- Policy objectives already met;
- Statutory expiration of the designation authority.
Petitions go through OFAC’s delisting portal with a cover letter, legal memo, written statements, and supporting documentary evidence. Initial review takes 60–90 days; classified-evidence cases stretch to 12–18 months. If OFAC denies or ignores a petition, an OFAC delisting lawyer can pursue judicial review in the U.S. District Court for DC under the Administrative Procedure Act (Al Haramain Islamic Foundation v. Treasury, 660 F.3d 1019).
Delisting Petition vs. License Application vs. Unblocking Request
| SDN Delisting Petition | Specific License | Unblocking Request | |
| Use when | You believe the designation itself is wrong or outdated | The designation is valid but you need to conduct a specific transaction anyway | Funds were frozen but no valid SDN match or blocking basis exists |
| Legal standard | Substantial evidence the designation no longer fits (APA § 706) | Transaction serves U.S. policy/national interest | Freeze was procedurally or factually mistaken |
| Typical timeline | 60–90 days (12–18 months if classified evidence) | 45 days (simple) to 90–180 days (complex) | Varies; often faster once error is documented |
| Outcome | Full removal from SDN List | One-time or category authorization; designation remains | Release of the specific frozen asset only |
Our Process: From First Contact to Resolution
- Case assessment — confirm whether the block stems from a genuine SDN match, a licensing gap, or a screening error, and identify the applicable deadline (pre-penalty notice, subpoena response, blocking report).
- Evidence compilation — gather identity documents, transaction records, corporate filings, and any prior compliance history relevant to the chosen strategy.
- Filing — submit the delisting petition, license application, or unblocking request with a supporting legal memorandum addressing OFAC’s specific evidentiary requirements.
- Agency follow-up — maintain direct contact with the assigned OFAC case officer; submit supplemental evidence as needed before a final determination.
- Escalation if denied — pursue reconsideration or, where appropriate, judicial review in the U.S. District Court for the District of Columbia under the APA.
Our Leading Attorneys
Dmytro Konovalenko, is a lawyer with many years of experience in dealing with the Interpol File Control Commission. Dmytro has successfully appealed for a red notice from countries of Europe, Asia, the Far East.
Anatoliy Yarovyi, lawyer, Doctor of Laws. Anatoliy specializes in appeals against INTERPOL Red Notices of North America, Latin America, Europe and Africa.
Why a Washington DC OFAC Attorney
Being based near Treasury, the Federal Reserve, and the DC District Court gives OFAC attorneys in Washington DC three practical advantages:
- Direct access — in-person meetings with OFAC compliance officers and licensing staff during negotiations;
- Litigation venue — most APA challenges to OFAC designations and penalties are filed in the District of Columbia, governed by D.C. Circuit precedent;
- Interagency coordination — working relationships across State, FinCEN, and Commerce accelerate license approvals and resolve jurisdictional overlaps.
FAQ
What triggers OFAC enforcement actions for financial institutions in Washington?
OFAC enforcement actions in Washington can be triggered by processing transactions involving SDN-listed parties, sanctioned jurisdictions, or failing to implement adequate sanctions screening and compliance controls required under U.S. regulations.
What penalties can companies in Washington face for OFAC violations?
Companies in Washington may face civil penalties of up to $356,579 per violation or twice the transaction value, as well as criminal penalties including fines up to $1 million and imprisonment for up to 20 years for willful violations.
When should a financial institution in Washington contact OFAC defense counsel?
A financial institution in Washington should contact OFAC defense counsel immediately when a potential SDN match is identified, a subpoena is received, or internal investigations reveal possible sanctions violations or compliance failures.
Can I request a license and a delisting petition at the same time?
Yes. A specific license can unblock an immediate transaction while a delisting petition proceeds separately — the two are not mutually exclusive.
What’s the difference between an OFAC unblocking request and a specific license?
An unblocking request argues the freeze was a mistake in the first place; a specific license asks permission for a transaction OFAC would otherwise legitimately block.
