Regulations
OFAC SDN List
OFAC launched its online Reconsideration Portal as the route for seeking removal from any OFAC sanctions list, including the SDN List, in June 2026.
A blocked person or property (or an authorised representative) can use the portal to request a “courtesy document” explaining the basis for a listing, or to submit a petition for administrative reconsideration (a “delisting petition”). OFAC is moving away from accepting petitions by e-mail, so the portal is now the recommended route, although OFAC has not yet announced a date by which e-mail submissions will stop being accepted.
The reconsideration process is only for people, entities and property that are actually listed. Anyone who has simply been mistaken for a listed person – for example, because of a similar name – should instead contact OFAC’s Compliance Hotline.
Courtesy documents
A courtesy document is a redacted, unclassified summary of the evidence OFAC relied on for a designation, or for denying an earlier delisting petition.
To request one, a listed person or representative should complete the basic information and contact details sections in the Reconsideration Portal and select “courtesy document” as the request type.
Some material may be withheld because it is classified, privileged, law-enforcement sensitive, or otherwise commercially sensitive.
Anyone (not only the listed person) can instead ask for the full evidentiary record by submitting a Freedom of Information Act (FOIA) request to the US Treasury.
Delisting petitions
There are 2 grounds for removal from an OFAC sanctions list:
- a change in circumstances; or
- an insufficient basis for the original designation.
- Change in circumstances
The sanctioned person must show that, since being listed, they have taken steps that remove the basis for the sanction – for example, resigning from a position they held when sanctioned, dissolving a listed entity, or stopping the activity that led to the listing.
A petitioner can also propose remedial steps it believes would achieve this, although a proposal alone is not a substitute for showing an actual change. In 2018, for example, OFAC agreed to delist EN+, Rusal and EuroSibEnergo after their parent company agreed to far-reaching corporate governance changes.
OFAC treats transferring assets to other sanctioned persons, or other sham transactions, as evidence that the underlying circumstances have not genuinely changed – and such steps may themselves be sanctionable. Anyone planning to transfer assets or divest from a sanctioned entity as part of a change in circumstances should coordinate with OFAC in advance.
- Insufficient basis
The petitioner must show that, at the time of listing, there was no proper basis for the sanction – for example, because of mistaken identity, or because the individual had already resigned, or the entity had already dissolved, before the sanction was imposed.
If a person or entity was sanctioned under more than one legal authority, or met more than one designation criterion, the petition must address each of these in order to succeed.
- Required information
A petition should always include:
- the listed name exactly as it appears on the relevant OFAC list, its unique identification number (UID) – found in the web address of the entry in OFAC’s Sanctions List Search tool – and the date OFAC added the listing;
- for individuals: full name as it appears on an official ID, proof of identity, all aliases, date and place of birth, addresses, e-mail and phone number;
- for entities or property (such as a vessel): full official name as it appears on registration documents, copies of those documents, all aliases, the registration date, addresses, e-mail and phone number; and
- where a representative is filing on the listed person’s behalf: the representative’s name and e-mail address, proof of authorisation (such as a power of attorney), and a description of the relationship.
Petitions are also strengthened by additional information such as sources of income, employment history, real-property ownership, social-media handles, contacts with other listed persons, banking details (including virtual currency), ownership structures, and a list of past and current owners, operators and managers.
OFAC’s review process
- Initial review: OFAC aims to check that a petition is complete within 7 to 10 business days. If it is, OFAC issues a Petition ID by e-mail; if not, OFAC asks for the missing information. Petitioners who hear nothing within 10 business days should contact OFAC.
- Full review: once a Petition ID has been issued, OFAC carries out a full reinvestigation. Timing varies depending on the facts of the case, how complete the original submission was, how quickly the petitioner responds, and whether OFAC needs to consult other government agencies.
- Questionnaires: OFAC may send one or more questionnaires, typically the first within 90 days of opening the case. Petitioners can ask for more time to respond, although extensions are not guaranteed, and missing a deadline – or failing to answer fully and honestly – can lead to denial.
- Outcome: OFAC will grant or deny the petition. If granted, the person, entity or property is removed from the list, the petitioner receives a notification letter, and the delisting is published on OFAC’s Recent Actions page and in the Federal Register. If denied, the petitioner receives a determination letter and may submit a new petition, but must present new arguments or evidence – simply repeating the same petition is likely to lead to another denial.
- False or misleading information: OFAC can deny a petition that contains inconsistent, misleading or false information, taking into account factors such as whether the information relates to the basis for the sanction, whether it forms part of a wider pattern, and how it affects OFAC’s ability to decide the case. Knowingly making false statements to OFAC can also lead to criminal liability.
In addition, SDN designation is a final agency action that may be challenged in federal court under the Administrative Procedures Act.
Useful resources
How to Request Removal from an OFAC Sanctions List
FAQs:
Quick-Reference Guide: What to Include in a Delisting Petition
Quick-Reference Guide: Delisting Petitions Best Practices
OFAC Compliance Hotline (for mistaken identity / name-match queries)
Sanctions Delisting – US Department of State (for designations made by the Department of State)
BIS List
BIS also maintains restricted parties lists, though the implications of listing are much more limited than the asset-blocking restrictions on SDNs designated by OFAC. The BIS lists are the Entity List, the Unverified List, and the Denied Persons List. Inclusion on these lists generally imposes a license requirement for exports, reexports, and transfers subject to the EAR, or a denial of US exporting privileges.
To request removal from the BIS “Entity List”, the listed person (or representative) must write to the End-User Review Committee (ERC) at Chair, End-User Review Committee, Bureau of Industry and Security, U.S. Department of Commerce, 14th Street and Pennsylvania Avenue, NW., Room 3886, Washington, DC 20230, detailing the reasons why the entity should be removed. Requests for removal from the Unverified List can be submitted via email to UVLRequest@bis.doc.gov, and must include information that verifies the bona fides, i.e., legitimacy and reliability of the person listed on the Unverified List as an end user, consignee or other party to exports, reexports, and transfers (in-country) of items subject to the EAR.
All BIS restricted parties lists, as well as restricted parties lists maintained by OFAC and the State Department can be searched at the Consolidated Screening List.