OFAC SDN List Removal
To be removed from the OFAC SDN List, you must file a Reconsideration Request under 31 CFR § 501.807. The process typically takes 6–18 months. Our lawyers have achieved removals in 90 days.
The Specially Designated Nationals (SDN) list, maintained by the U.S. Office of Foreign Assets Control (OFAC), includes individuals, organizations, and companies subject to U.S. sanctions. Being placed on this list can have serious consequences for both individuals and entities, as it freezes their assets and restricts their access to financial markets.
Thanks to their experience and deep knowledge in dealing with the field of foreign policy, national security, and sanctions programs and laws acting on behalf and against entities and organizations, our lawyers will help you navigate this process and protect your interests by acting on behalf of the foreign policy, national security, and acting on behalf of national security international sanctions programs and sanctions stage acting against entities and organizations.
If You’re Already on the SDN List, Here’s What’s at Stake
Every day your name or company stays on the SDN List, the damage compounds. Banks close accounts on sight, business partners quietly walk away, and international transactions stop clearing — often before you’ve even had a chance to explain the designation is a mistake or no longer applies. The longer a case sits unaddressed, the more the delisting petition has to overcome: lost banking relationships, disrupted contracts, and, in some cases, additional scrutiny simply because the designation has remained unchallenged for so long.
A Reconsideration Request is a formal, evidence-based legal filing — not a form you submit and wait on. The strength of the petition, and how quickly it’s filed, directly affects how long OFAC takes to respond.
What is the OFAC SDN list?
SDN stands for Specially Designated Nationals. The list, maintained by the U.S. Office of Foreign Assets Control (OFAC), identifies individuals, companies, and organizations that the U.S. government has determined are connected to activities such as terrorism, weapons proliferation, narcotics trafficking, corruption, or sanctions evasion.
To understand the procedure and necessary documents for removal from the SDN list, download our detailed PDF instructions.
Main functions of the SDN list
- Freezing of assets. All assets of individuals and companies that fall under the SDN list are frozen. No person or organization within the US can carry out financial transactions with individuals or companies on this list.
- Trade operation restrictions. American companies are prohibited from doing business with those on the SDN list. This fact significantly complicates international trade for such entities.
- Fighting Global Threats. The primary goal of the list is to protect U.S. national security and counter global threats such as terrorism, corruption, and human rights abuses. The SDN list is a crucial tool in combating the financing of terrorism and other illicit operations.
Legal Grounds for Removal from the SDN List
FAC will only grant a delisting petition if it is built on a recognized legal basis. The most common grounds include:
- Mistaken identity — the designation resulted from incorrect identification or wrongful association with a sanctioned party;
- Change in circumstances — the individual or company has genuinely severed all ties to the sanctioned conduct or parties that led to the designation;
- Remedial action — corrective steps have been taken, such as a change in ownership, management, or business activity;
- Legal or factual error — the original designation was based on incomplete, outdated, or inaccurate information.
Steps in the SDN List Removal Process
- Case analysis. We review OFAC’s published basis for the designation and identify which legal ground applies to your situation.
- Evidence gathering. We collect documentation supporting your case — corporate records, correspondence, financial records, or evidence disproving the alleged connection.
- Drafting the Reconsideration Request. The petition is prepared under 31 CFR § 501.807, presenting a clear legal argument supported by evidence.
- Submission and follow-up. The petition is filed with OFAC, and we manage all subsequent correspondence and requests for additional information.
- Decision and next steps.If the petition is granted, the designation is removed. If denied, we assess the grounds for denial and prepare a resubmission or appeal.
Do You Need a Lawyer to File a Reconsideration Request?
No — OFAC accepts petitions directly from listed persons or their representatives, and legal representation is not a formal requirement. But a petition is only as strong as the legal argument and evidence behind it. OFAC evaluates each case individually against the same regulatory standard (31 CFR § 501.807), and a self-filed petition that misses the right legal ground, omits key evidence, or fails to respond fully to a follow-up questionnaire is far more likely to be denied or delayed for months.
There’s also a detail most people don’t expect: attorneys representing an SDN generally need their own OFAC authorization to be paid for that work, since payment itself is a transaction involving a blocked person’s interests. Firms that handle SDN removal regularly already operate under the applicable general license — it’s one more reason experienced counsel moves faster than a first-time filer.
Common Reasons for SDN Designation
Understanding why designations happen also helps prevent them. The most frequent triggers we see include:
- Business or family ties to an already-sanctioned individual or entity, even where the designated party had no direct involvement in the sanctioned conduct;
- Outdated open-source information — news reports or allegations that no longer reflect current facts but were relied on at the time of designation;
- Ownership or control by a sanctioned party, even indirectly, through a corporate structure;
- Insufficient sanctions screening by a business that unknowingly facilitated a transaction later tied to a sanctioned party.
If you believe you may be at risk of designation before it happens — for example, if media reports are linking you to a sanctioned party — we can also help present your case to OFAC proactively, before a designation is issued.
Which Agency Reviews Your Case?
Not every SDN designation is adjudicated the same way. Petitions are always submitted to OFAC first, which assigns a case number — but if the underlying designation was made by the State Department (in consultation with Treasury) rather than OFAC itself, the State
Department becomes the Adjudicating Agency and conducts the actual review. Knowing which agency is deciding your case — and tailoring the petition accordingly — affects both the evidence you should submit and what to expect during the review.
Preparing and Filing an OFAC Petition
A petition to OFAC is a formal request for reconsideration of a sanctions designation, or for a license to carry out an otherwise prohibited transaction. Preparation typically involves three stages: analyzing the circumstances that led to the designation, gathering supporting evidence, and building the legal arguments for removal.
Once submitted, OFAC’s review can take anywhere from a few months to several years, depending on the complexity of the case. Staying in active, ongoing communication with OFAC throughout the review — responding promptly to any request for additional information — is one of the most effective ways to keep a case moving and avoid unnecessary delay.
- Mistaken identity: an individual or company was added to the list due to incorrect identification or wrongful association with sanctioned entities;
- Changes in circumstances: for example, if a company has severed any ties with sanctioned organizations or individuals, this could be grounds for reviewing its status on the list;
- Implementation of corrective measures: The individual or company has addressed all the violations that were the basis for imposing sanctions (changes in management or ownership structure, discontinuation of certain types of activities);
- Rectifying previous violations: may involve both financial and legal obligations;
- Petition to OFAC: The petition should include well-reasoned arguments for removal from the SDN list and contain evidence supporting the claim that there are no longer grounds for remaining on the list.
SDN List Removal Attorneys: Why Work With Our Firm
- Track record of faster outcomes. While the standard OFAC review takes 6–18 months, our attorneys have secured removals in as little as 90 days through well-documented, thoroughly prepared petitions.
- Deep sanctions law experience.Our team focuses specifically on OFAC and international sanctions matters, not general litigation — this is the core of our practice.
- Full case management. We handle every stage — case analysis, evidence gathering, petition drafting, submission, and any appeal — so you have a single point of contact throughout.
- Cross-border sanctions coverage. Many designations involve exposure under multiple regimes. If your case also touches UK sanctions, see our UK Sanctions Lawyer (OFSI) services.
- Related services. If your assets are currently frozen while your delisting petition is pending, our OFAC Blocked Assets team can help address immediate access to funds in parallel.
Frequently Asked Questions
What is the SDN list?
SDN stands for Specially Designated Nationals — the list maintained by OFAC identifying individuals and entities subject to U.S. sanctions.
How do I appeal an OFAC SDN designation?
There is no traditional court appeal. Instead, you file a Reconsideration Request directly with OFAC under 31 CFR § 501.807, presenting legal and factual arguments for why the designation should be lifted.
How long does OFAC delisting take?
The standard timeline is 6–18 months, though this varies based on case complexity and how thoroughly the initial petition is prepared. Well-documented petitions with a clear legal basis tend to move faster.
Can a company be removed from the SDN List, or only individuals?
Both. Companies, vessels, and other entities can be designated and can file for removal just as individuals can, though the evidence required often differs — for example, showing a change in ownership or management structure.
Do I need a lawyer to file a Reconsideration Request?
It is not legally required, but OFAC petitions are evaluated on the strength of the legal argument and evidence presented. A poorly supported petition is more likely to be denied or delayed, which is why most parties engage counsel with direct OFAC experience.
What if my OFAC petition is denied?
A denial is not final. You can request the specific grounds for denial and prepare a resubmission that addresses them directly, or, in some cases, pursue further administrative or legal remedies.
How long until I hear back after filing?
OFAC typically confirms receipt within about a week for email submissions. If additional information is needed, the first follow-up questionnaire is usually sent within 90 days of the case being assigned a number — though the full review can still take much longer.
