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The formal removal of a person, entity, or vessel from a U.S. Treasury sanctions list maintained by the Office of Foreign Assets Control.
The U.S. Treasury's Office of Foreign Assets Control (OFAC) administers most U.S. economic sanctions, including the Specially Designated Nationals and Blocked Persons (SDN) List and various sectoral and country-based lists. Delisting is the administrative or diplomatic process by which OFAC removes a name from one of these lists, unblocking property and lifting prohibitions on U.S.-person dealings with the target.
Delisting can occur through several pathways:
OFAC publishes a "Recent Actions" feed announcing additions and removals. A delisted party regains access to blocked funds (subject to liens, third-party claims, and any remaining secondary sanctions exposure), but reputational and banking-compliance effects often linger because correspondent banks continue de-risking.
Delisting is politically sensitive. Congress has at times sought to constrain executive discretion — for instance, through notification requirements in the Countering America's Adversaries Through Sanctions Act (CAATSA) of 2017, which imposed congressional review on certain Russia-related delistings. High-profile examples include the 2019 removal of entities tied to Russian oligarch Oleg Deripaska (EN+, Rusal, EuroSibEnergo) after governance changes, and removals tied to the 2015 Joint Comprehensive Plan of Action with Iran, many of which were reversed in 2018.
There is no statutory deadline. In practice, petitions under 31 C.F.R. § 501.807 often take many months to several years, depending on case complexity and the policy environment.
Yes, the legal block is lifted, but actual release depends on the holding bank's compliance review, competing creditor claims, and any overlapping sanctions from other jurisdictions such as the EU or UK.
Under CAATSA, certain Russia-related delistings require advance notice to Congress, which can pass a joint resolution of disapproval; the 2019 Deripaska-linked removals proceeded after such a resolution failed in the Senate.