A New Beginning: OFAC And Its New Reconsideration Portal For Persons, Property, And Vessels Who Want To Delist From The SDN List

On June 29, 2026, the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) launched a new online reconsideration portal through which individuals, property, or vessels can submit requests to be removed from the Specially Designated Nationals (“SDN”) list. The new process promises significant improvement in SDN delisting procedures.

In a prior client alert, To (Try and) Delist or not Delist: That is the Question!, we explained how a person, property, or vessel could be removed from the SDN List if they followed the procedures set forth in 31.C.F.R. §501.807. The procedures include submitting a petition with detailed arguments and evidence that shows “an insufficient basis exists for the sanction or the circumstances resulting in the sanction no longer apply.” After submission, the petitioner is required to wait for a decision from OFAC. If the petition is granted, there is nothing extra one needs to do (aside from due diligence to ensure removal). If the petition is denied, however, a two-step administrative appeal process would be available. If the appeal is unsuccessful, the petitioner could challenge the OFAC’s decision in federal court.

Now, through the new online portal, petitioners can either obtain a courtesy document or submit a petition for administrative reconsideration, also known as a delisting petition or reconsideration request, on their own or through an authorized representative. Regarding the courtesy document, persons, property, or vessels can now request, and OFAC will prepare, information regarding the underlying OFAC sanctions determination. The courtesy document will contain a list of exhibits that identifies unclassified, non-privileged information underlying OFAC’s determination. If for some reason the petitioner fails, is unaware, or does not request a courtesy document and subsequently wants a copy of the documents, the evidentiary record underlying a sanctions determination can be received by submitting a Freedom of Information Act (“FOIA”) request to the United States Department of Justice.

For those who choose to submit a delisting petition, the petition must state the following basic information: (i) the name as it appears on the OFAC sanctions list; (ii) the unique identification number (“UID”) found in the OFAC’s Sanctions List Search tool; and (iii) the date OFAC listed the relevant name. If the sanctioned party is an individual, the petitioner should also include any aliases, place of birth, date of birth, physical mailing addresses, email addresses, and telephone numbers.

If the sanctioned party is an entity or property, the petition should include the: (i) full official name as it appears in government registration documents; (ii) official registration documents, including any business licenses, aircraft and/or vessel registration numbers; (iii) any aliases; (iv) physical and mailing addresses; (v) email addresses; and (vi) telephone numbers. Finally, if an authorized person is submitting a petition on behalf of an individual or property, the petition should include the: (i) authorized representative’s name and address; (ii) proof of authorization to represent the listed person or property; and (iii) a description of the representative’s relationship or property.

The petitioner should still submit arguments and evidence that demonstrate there are justified reasons for removal from the SDN List, including (a) the circumstances resulting in the sanction no longer apply (“change in circumstances”) or (b) that an insufficient basis exists for the sanction. A change in circumstances means after the sanction was imposed, the sanctioned person took steps to remove the basis for the sanction or that the circumstances underlying the sanction otherwise changed. It does not mean transferring assets to other designated or blocked persons or other sham transactions which may be viewed by OFAC as sanctionable conduct.

Within seven (7) to ten (10) days of the petition being submitted via the online portal, OFAC will conduct an initial review of the delisting submission to ensure all the relevant information is included in the petition. If any information is missing, OFAC will contact the petitioner or authorized person to get additional information. If the delisting petition is complete, OFAC will issue the petitioner a Petition Identification Number (“PIN”) and a full comprehensive review of the delisting petition will begin. The process can be lengthy and depends on numerous factors, including the specific facts of the case, the thoroughness of the initial delisting petition submission, the petitioner’s timeliness and candor in responding to any OFAC questionnaires and requests, and any consultation between OFAC and other governmental agencies.

While the process appears to be daunting, OFAC’s new portal was established “to improve the process and bring greater transparency and efficiency to the adjudication of its petitions.” Not only will the process be faster, but, in time, the online portal will replace the older email submission process.