OFAC’s New Reconsideration Portal: A Path to Delisting
Parties designated by OFAC must understand the new reconsideration portal’s procedures and evidentiary standards to effectively petition for removal from the Specially Designated Nationals List.
OFAC has launched a formal reconsideration portal for parties seeking removal from the Specially Designated Nationals (SDN) List. The portal establishes a structured process for submitting petitions, including specific requirements for evidence demonstrating a change in circumstances, mistaken identity, or that the basis for designation no longer applies. This shift from informal channels to a centralized digital system introduces new procedural rules and timelines. Designated parties and their counsel must now navigate this formal process, ensuring submissions meet OFAC’s criteria to avoid rejection. The portal’s existence signals OFAC’s move toward greater transparency and efficiency in delisting decisions, while raising the bar for the quality and organization of petition materials.