Federal lawsuit filed to compel OFAC action on delayed delisting petition
Situation:
Ferrari & Associates filed a civil complaint in the United States District Court for the District of Columbia on behalf of Captain Alireza Rahnavard, an Iranian national designated by OFAC under Executive Order 13599 based on alleged ties to the National Iranian Tanker Company and the vessel FORTUNE. The client had previously submitted a petition for administrative reconsideration under 31 C.F.R. § 501.807 and fully responded to OFAC follow-up requests, yet the agency failed to issue a determination despite extended delays and repeated status inquiries.
Stakes:
The continued SDN designation carried significant personal and financial consequences, including restrictions on financial access, reputational harm, cross-border limitations, and ongoing sanctions exposure tied to unresolved OFAC action. The absence of agency resolution left the client in procedural limbo while the designation remained active. The matter also raised broader concerns regarding administrative delay, due process, and the ability of designated parties to obtain meaningful review of OFAC determinations.
Result:
Ferrari & Associates initiated federal litigation seeking judicial intervention to compel OFAC to act on the pending reconsideration petition within a reasonable timeframe. The filing added to the firm’s active sanctions litigation docket before the D.D.C. and reinforced its broader practice representing clients in challenges involving OFAC enforcement actions, designation disputes, and agency inaction. The matter positioned the client to pursue relief through both administrative and judicial channels simultaneously while increasing pressure for agency review.
