OFAC Attorney: There is no set timetable for being removed from the SDN list. Sometimes a person can be removed in a matter of months, but usually it can take between one to three years. However, removal is not automatic. To be removed from the SDN list, a person must first seek administrative reconsideration of their designation from OFAC. To do this, a designated person must file a reconsideration request to OFAC pursuant to the regulation under 501.807. The reconsideration request must credibly demonstrate to OFAC that insufficient basis exists for the designation or propose remedial steps that the person believes would negate the basis for their designation. Unlike a judicial or court filing, a person seeking removal from the SDN list must go before the very agency that authorized the designation in the first place, OFAC. The process can be both factually and legally intensive without the assistance of an attorney.
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