OFAC delisting and administrative reconsideration

Who can file and who cannot

OFAC says administrative reconsideration is solely for persons or property, through authorized representatives, that appear on one of its lists ¹. The regulation lets a blocked person, or a person owning a majority interest in a blocked vessel, submit arguments or evidence ².

A person who was confused with a listed person, for example through a close name match, is outside this process. OFAC directs them to its Compliance Hotline ³. People who are not listed and want information about a designation must use a Freedom of Information Act request ¹.

What a petition has to show

The regulation allows evidence that the sanction lacks a sufficient basis or no longer applies. It allows proposals for remedial steps, such as corporate reorganization or resignations from blocked entities ². OFAC's guidance page frames the test as a change in circumstances or an insufficient basis ¹. A petition covering more than one authority must address each one ¹. Proposed remedial steps on their own do not establish a change in circumstances ¹.

OFAC asks for the listed name, the unique identifier (UID) and the listing date. Individuals provide identity documents, aliases, birth details and addresses. Representatives provide proof of authority such as a power of attorney ¹.

Steps and published target times

• Confirm the entry on OFAC's Sanctions List Search tool, with name, UID and listing date ¹.
• Submit the petition. The OFAC guidance page directs filers to the Reconsideration Portal ¹.
• Completeness check. OFAC aims to review submissions within 7 to 10 business days and then sends a Petition ID or asks for missing items ¹.
• Full review. OFAC typically aims to send its first questionnaire within 90 days of opening a petition. Missed deadlines or incomplete answers may lead to denial ¹.
• Meeting. A petitioner may ask for a meeting, but OFAC is not required to hold one ².
• Decision. OFAC gives a written decision ².

Portal or email: two official descriptions

Official texts describe the filing channel in different ways. The regulation, in the 1 July 2025 edition of the Code of Federal Regulations, says submissions must be made by email to OFAC.Reconsideration@treasury.gov ². OFAC's current guidance page and FAQ 897, updated 29 June 2026, direct petitions to the Reconsideration Portal ^1,3. The State Department page, last modified 30 December 2024, tells petitioners to email or mail OFAC at the same address ⁵. OFAC says it sends the Petition ID and any requests for more information by email ¹.

Outcomes, refiling and false statements

If OFAC grants a petition, the party is removed, receives a notification letter, and the removal is published on the Recent Actions page and in the Federal Register ¹. If OFAC denies it, the party receives a determination letter ¹.

A denied party may petition again using the same process. The new petition needs new arguments or evidence, or OFAC may deny it by referring to the earlier decision ⁴. OFAC warns that knowingly making materially false statements may bring criminal penalties under 18 U.S.C. 1001 ¹.

OFAC's guidance page and FAQs give no count of petitions received, granted or denied ³.

State Department designations

Some listings on OFAC-administered lists are made by the State Department. The adjudicating agency depends on the authority used ⁵. Even then, the first step is writing to OFAC, which assigns a case number and forwards the petition to State ⁵. State typically aims to send its first questionnaire within 90 days of case-number assignment and aims to reply to status emails within two business days ⁵.