What Is the SDN List?

The Specially Designated Nationals and Blocked Persons List (SDN List) is maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). It includes names of individuals, companies, vessels, and organizations believed to be involved in:

• Terrorism
• Narcotics trafficking
• Weapons proliferation
• Corruption and human rights abuses
• Cybercrime, foreign election interference, and more

Once you’re on the list, your U.S.-linked assets are frozen. U.S. citizens and businesses are prohibited from doing business with you. And because of global compliance rules, most international banks and companies follow the same restrictions.

 

How You End Up on the SDN List

Designations come from Executive Orders or laws like:

• The Global Magnitsky Act (human rights and corruption)
• The Kingpin Act (drug trafficking)
• Executive Order 13818 (cybercrime, election interference)
• Executive Order 14024 (Russian malign activity)

You don’t need to be a U.S. citizen to be sanctioned — many people are added due to actions outside the United States, including political affiliations, economic activities, or associations with other sanctioned parties.

OFAC doesn’t have to give advance notice. You find out when your bank account is frozen, your name is blocked from payments, or you see it published on the official list.

 

The Immediate Fallout

Being on the SDN List causes instant, widespread impact:

• All U.S.-based assets are blocked, including bank accounts, real estate, and contracts
• Any entity that you own 50% or more of is also considered blocked
• International banks and partners may sever ties to avoid “secondary sanctions.”
• Your ability to travel, trade, or operate in the global financial system is nearly destroyed

Is It Permanent?

Not necessarily. While SDN listings are serious, they are not always permanent. OFAC allows individuals and companies to file for administrative removal, and some designations have been successfully reversed.

OFAC encourages individuals to petition for delisting if the basis for designation no longer applies or if there’s a case of mistaken identity.

Making a Delisting Request: The Formal Route

The removal process starts with a Petition for Delisting under 31 C.F.R. § 501.807. The steps include:

Step 1: Write the Petition

You must submit a detailed request to OFAC explaining:

• Why the designation is no longer valid
• Any factual errors in OFAC’s claims
• Documentation proving a change in behavior or dissociation
• Evidence of reforms, audits, or lawful conduct

Step 2: Attach Supporting Evidence

OFAC expects documentation. This may include:

• Affidavits
• Financial audits
• Compliance program details
• Legal opinions
• Termination of problematic business relationships

Step 3: Wait and Respond

After submission, OFAC reviews the request. They may ask for additional evidence, clarification, or interviews. This can take months or even years.

If denied, you can re-petition with new facts or pursue legal action in U.S. courts.

 

Building a Strong Case for Delisting

Here’s what successful petitions often include:

Clear Behavioral Change

If the person or entity has genuinely ceased the activities that led to the sanctions (e.g., terminated business with sanctioned entities, stopped public corruption, or ceased human rights violations), this should be front and center.

Demonstrated Compliance Reforms

The creation of robust compliance and monitoring systems, such as internal anti-money laundering controls, external audits, or legal restructuring, strengthens credibility.

Third-Party Endorsements

Statements from lawyers, neutral observers, or governmental officials not involved in the original designation can help shift the narrative.

 

Real-World Success Stories

While rare, delisting happens. Notable examples include:

• EN+, a major Russian energy company, was removed from the SDN List after its founder, Oleg Deripaska, reduced his ownership and control.
• Individuals who cooperated with international authorities or withdrew from political or military activities have also seen success.

These cases show that legal strategy, negotiation, and proof of change can lead to outcomes.

Can You Challenge the SDN Designation in Court?

Yes, though it’s not the first path most take. Some individuals and companies have sued OFAC, claiming:

• Inaccurate or outdated evidence
• Violation of constitutional rights (e.g., due process)
• Mistaken identity or misapplied law

Courts have occasionally sided with petitioners, especially in cases where OFAC failed to follow proper procedure or relied heavily on circumstantial information.

Alternatives to Full Removal

Even if you can’t get removed from the SDN List entirely, you may qualify for certain specific licenses, such as:

• Paying legal fees
• Selling frozen property
• Receiving humanitarian funds
• Conducting limited business under supervision

Applying for these licenses is separate from the delisting process and is often used to ease restrictions temporarily.

 

Strategic Considerations

If you or your business is sanctioned:

• Do not try to hide assets or use aliases — this can lead to criminal charges
• Retain experienced legal counsel who knows U.S. sanctions law
• Prepare for a long process, but start it immediately — delay only increases reputational and financial damage

Delisting from the SDN List isn’t just about paperwork — it’s about presenting a compelling case backed by legal precision and documented reform. Lionel Iruk, Esq., General Counsel at Empire Global Partners, has led high-profile delisting efforts by combining structured legal arguments, third-party audits, and strategic diplomatic outreach. His team ensures that every petition is more than a request — it’s a comprehensive legal defense.
Being listed on the SDN List isn’t just a penalty — it’s a system-wide exclusion. But it’s also a legal and political designation that can be challenged, negotiated, and, in some cases, reversed.

With the right strategy, documentation, and commitment to reform, individuals and companies can navigate the path back to legitimacy. The key is understanding that time, transparency, and legal expertise are your most valuable assets.