Cyber-related sanctions removals secured with post-delisting asset recovery
Situation:
Ferrari & Associates represented multiple individuals designated under OFAC’s cyber-related sanctions authorities in administrative reconsideration proceedings pursuant to 31 C.F.R. § 501.807. The clients sought removal from the SDN List after demonstrating they were no longer engaged in the sanctioned conduct underlying the designations.
Stakes:
The designations resulted in blocked financial accounts, frozen property interests, severe banking restrictions, reputational harm, and limitations on conducting business internationally. Even after removal from the SDN List, clients faced additional operational and financial obstacles tied to previously blocked assets and institutional compliance concerns. The matters required not only successful delisting, but also coordinated post-delisting remediation to restore access to property and financial systems.
Result:
Ferrari & Associates secured the removal of two individuals from OFAC’s SDN List under the cyber-related sanctions program following extensive administrative advocacy and evidentiary submissions. After delisting, the firm continued representing the clients in post-designation matters involving the release of frozen financial accounts and real property interests. Ferrari & Associates continues to represent additional individuals designated under the same sanctions authorities as they navigate the OFAC reconsideration process and related compliance consequences.
