OFAC Delisting

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:

• Petition for reconsideration under 31 C.F.R. § 501.807, in which a listed party submits arguments and evidence that the basis for designation is inaccurate, that circumstances have changed, or that the party has taken remedial steps (severing ties with sanctioned actors, changing ownership, paying penalties, adopting compliance programs).
• Policy-driven removal, when the U.S. executive branch decides that sanctions no longer serve foreign-policy goals — for example, as part of a negotiated agreement or normalization.
• Judicial review in U.S. federal court, though courts have generally been deferential to OFAC under the Administrative Procedure Act and IEEPA.
• Automatic expiration when an underlying executive order or statutory authority lapses.

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.