Can You Get Off the SDN List?
from Corruption Crime & Compliance Hosted by Michael Volkov
Has OFAC branded your company with the scarlet letter? Getting removed from the SDN list is possible, but it’s not fast, it’s not easy, and it’s not guaranteed. The primary path is a petition for administrative reconsideration filed with OFAC, arguing mistaken identity, changed circumstances, or that the original factual basis was simply wrong. You must prove it with real documented evidence. OFAC is skeptical of cosmetic restructurings designed to look like change while control remains the same. Practically, petitions can take many months to over a year, and you’re often arguing against evidence you’ll never fully see, since designations can rest on classified information. If OFAC denies or ignores your petition, you can challenge it in federal court, but courts defer heavily to the executive on sanctions, so litigation is a last resort, not a strategy. If you’re designated, get experienced OFAC counsel immediately, do a real internal investigation, build your remediation story, and manage expectations. It takes time. The best strategy is never needing this. Build a sanctions program rigorous enough that you never end up on the list at all. The Ethics and Compliance Q and A show is produced by One Stone Creative.
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