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OFAC SDN List Removal

Being Placed on the OFAC SDN List has been Called an Economic Death Sentence, But it Doesn't Have to Be

Being designated and identified on the OFAC SDN List can be devastating. In addition to the immediate economic consequences it brings, it can completely destroy a company or person’s reputation and relationships. While the designations are sudden and severe, there is an administrative process for removal from the OFAC SDN List. If a targeted party can show either a factual or legal mistake in the designation or can demonstrate or propose a change of circumstances that negates the basis of the designation, they have a good chance of being removed. The OFAC lawyers at Ferrari & Associates specialize in this specific type of OFAC case and have been highly successful in seeking the removal of parties designated under a variety of sanctions programs.

Ferrari & Associates has recently represented parties in the following types of OFAC SDN List removal matters:

  • Removed major shipping line, owner of shipping line, and his family from the OFAC SDN List following their designations pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act).
  • Removed South East Asian infrastructure conglomerate and entity’s owner from OFAC SDN List, following their designation pursuant to an executive order issued pursuant to the International Emergency Economic Powers Act (IEEPA).
  • Removed a Presidential Tier I designation under the Kingpin Act of a Central American businessman that owned large scale hospitality and infrastructure business operations.
  • Represented a major Central American retail group, their owner, and his son in seeking an administrative reconsideration of their designation under the Kingpin Act.
  • Removed a former government official of an African nation from the OFAC SDN List following his designation under an executive order issued pursuant to the IEEPA and the United Nations Participation Act ("UNPA").
  • Removed the chief financial officer/accountant of a counter-proliferation target from the OFAC SDN List following their designation by OFAC under an IEEPA-based executive order, as well as by the United Nations.

Ferrari & Associates has also assisted clients in presenting their cases to OFAC before a designation has occurred. This type of representation usually arises when open source reporting is alleging that the party is engaged in sanctionable conduct or has dealings with sanctioned parties. In doing so, we have been able to successfully keep parties from being designated by providing OFAC with information and evidence showing that the allegations are not true or that the circumstances have changed to render any sanctions designation unwarranted. If you believe that media outlets, NGOs, or other parties are falsely publishing derogatory information about you or your company that may lead to a sanctions designation, call us today to assist you in presenting your case to OFAC, to try to prevent a sanctions designation before it is too late. 

If you are in need of assistance in being removed from the OFAC SDN List or if you have questions on how to seek delisting from OFAC, do not hesitate to contact us.