New OFAC de-listing guidance

OFAC has updated its guidance / FAQs on the procedure for applying to be removed from its sanctions / SDN lists.  The FAQs say that OFAC de-lists 100s of entities each year (which was not the case until recently), and that the purpose of designation is not punitive but to change behaviour (the most frequent basis for delisting is that the SDN has stopped the behavior that led to designation).

This entry was posted in USA by Maya Lester QC. Bookmark the permalink.

About Maya Lester QC

Maya Lester QC has a wide ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. As the most recent (2016) Chambers & Partners directory put it, she "owns the world of sanctions". She spent 2011-12 in New York at Columbia Law School lecturing and writing on sanctions. She represents and advises hundreds of companies and individuals before the European and English courts and has acted in most of the leading cases, including Kadi, Tay Za, Central Bank of Iran, NITC and IRISL.

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