THE CHALLENGE
Removal is not automatic, even when facts change or the original basis was wrong. OFAC applies a high bar. Petitions must directly answer the designation criteria, close factual gaps, and show credible, verifiable change or error. Thin records and procedural missteps can stall matters for years and weaken leverage at every stage.
How does this get solved?
Outcomes change based on how the record is built from day one. We develop evidence and arguments for real scrutiny, including judicial review, even when the goal is resolution through OFAC’s administrative process. Former OFAC perspective shapes what to prove, where the weak points will be, and when escalation is necessary. Because delisting often collides with business constraints, the strategy coordinates licensing, unblocking, and counterparty continuity so operations do not stall while the petition moves.
Rapid intake of listing matters
When a listing event occurs, the priority is stabilizing facts and preserving a clean, consistent record. We move quickly to understand the designation basis, align internal stakeholders, and coordinate next steps with banks and key counterparties.
Initial intake typically includes: designation basis and identifiers, ownership and control, key counterparties, bank communications and freeze details, transaction history tied to the issue, and prior OFAC submissions or license applications.
our approach
How we build a delisting record
Clarify the record
What changes outcomes is how the record is built from day one. Evidence and arguments are developed for real scrutiny, including judicial review, even when the goal is to resolve the matter within OFAC’s administrative process. Former OFAC perspective shapes what to prove, where the weak points will be, and when escalation is necessary. And because delisting often collides with real-world business constraints, the strategy is built to coordinate licensing, unblocking, and counterparty continuity so operations do not stall while the petition moves.
Build the submission
Identify what OFAC relied on and what the designation actually alleges. Pinpoint the gaps to close, the assumptions to rebut, and the criteria the petition must meet. Map the fact pattern, ownership and control, counterparties, and transaction flow so the theory is coherent and verifiable. Set the strategy early so declarations, supporting documents, and any public-facing messaging stay aligned.
Drive the decision
File through the right channel and manage the process through follow-ups, supplemental submissions, and agency questions. Control pacing, keep the record consistent, and avoid resets caused by incomplete or conflicting submissions. Coordinate parallel needs that affect continuity, including licensing, unblocking, and counterparty communications, while the delisting petition advances. Prepare escalation if the process stalls, including litigation strategy when the facts and posture support it.
Latest outcomes
Outcomes that keep you operational
Humanitarian operations preserved amid terror-financing designation threat
A large international humanitarian relief charity facing threatened OFAC designation on terror-financing allegations prevented listing through pre-designation advocacy, credible counter-terrorist-financing procedures, and resolution of frozen charitable transfers.
SEE THE DETAILS
Platform operations secured amid sanctioned-party access allegations
A global cryptocurrency exchange facing threatened OFAC designation for sanctioned-party access prevented listing through coordinated pre-designation defense, independent investigation, and transparent agency engagement.
SEE THE DETAILSSeeking delisting or SDN removal?
We build the record, manage the process, and coordinate continuity issues so the business isn’t forced into limbo.