US District Court rejects Afghan sanctions delisting application – Nabizada v Rubio

1 September 2026

The US District Court for the District of Columbia has rejected Kamaluddin Nabizada’s claim to set aside his designation on the US Counterterrorism list under EO 13224 and OFAC’s denial of his 2022 delisting application – Kamaluddin Nabizada v Rubio (No. 23-02906 (AHA)).

Mr. Nabizada was designated in May 2022 for providing financial support to the US-sanctioned Islamic Revolutionary Guard Corps-Qods Force.  In October 2022 he applied for OFAC to reconsider the decision, which was rejected in 2024. See our US delisting page for more information on the application process.

Mr. Nabizada challenged both his designation and the denial of his application before the Court, saying that OFAC had acted arbitrarily and capriciously (in breach of the Administrative Procedure Act) by using false and irrelevant evidence to justify his designation and to reject his application. He also argued that it had breached his due process rights by not sharing classified information on which the designation was based.

The Court dismissed all Mr. Nabizada’s claims and granted the Government summary judgment. The Court said that OFAC’s reasons for denying the application were well reasoned. Mr. Nabizada had not provided credible evidence to challenge his designation. The reason he provided for his delisting (that he was not involved in a corruption scheme related to Kabul Bank) did not undermine the reason for his designation (that he provided funds to the IRGC-QF by selling oil on behalf of senior officials).

The Court also said the government does not need to disclose information classified for reasons of national security to avoid a breach of due process (citing Holy Land Found for Relief & Dev. v. Ashcroft). All US delisting judgments are on our US judgment page. See our US de-listing webinar for more information on the delisting process.