Sanctions & Delisting

Terrorism-related sanctions can freeze assets, interrupt payments, end correspondent relationships and isolate an organization before there is a judicial proceeding. We advise designated persons and entities, banks, businesses, charities, NGOs and individuals on the legal and factual questions that follow an OFAC alert, blocking action, rejected transaction, subpoena or designation.

The first step is to identify the governing authority and the precise restriction. OFAC administers multiple sanctions programs under statutes and executive orders, and the answer may depend on the program, the parties, the property interest, the location of funds and the role of U.S. persons. We analyze direct listings, aliases, ownership interests, OFAC’s 50 Percent Rule, indirect dealings, facilitation, funds transfers and reporting obligations. Where another jurisdiction is involved, the team coordinates with qualified foreign counsel and considers authorities such as the United Kingdom’s HM Treasury Office of Financial Sanctions Implementation, while avoiding the assumption that one jurisdiction’s authorization controls another.

Licensing and humanitarian work require equally careful analysis. A general license may authorize a defined category of transactions subject to conditions; another activity may require a specific license. Medicine, medical services, remittances, nongovernmental activity, food, agricultural commodities and humanitarian operations can be addressed differently across programs and authorizations. We document the intended transaction, parties, financial route, end use, ownership and monitoring controls before advising whether activity may proceed or whether an application, interpretive request or agency engagement is appropriate.

For designation challenges, 31 C.F.R. § 501.807 provides a process for seeking administrative reconsideration of a designation or asserting that circumstances resulting in the designation no longer apply. A persuasive petition is more than a denial. It organizes verifiable evidence, addresses the apparent basis for designation, explains governance or behavioral changes when relevant, and responds fully to agency questions. Because business partners and financial institutions may make their own risk decisions, the legal strategy also includes accurate communications that do not overstate what a petition or license accomplishes.

Sanctions advice must be transaction-specific. A license, exception or delisting petition should never be described more broadly than its actual legal effect.

What we do

We handle urgent transaction questions and longer administrative processes, always connecting sanctions advice with criminal, BSA/AML, contractual and reputational consequences.

1. Terrorism sanctions analysis under applicable executive orders, regulations, general licenses and published agency guidance.
2. Blocked versus rejected transaction advice, required reporting, record preservation and communications with financial institutions.
3. Direct and indirect ownership analysis, aggregation under the 50 Percent Rule and control-related risk assessment.
4. Specific-license applications, interpretive requests and documentation of conditions for authorized humanitarian or commercial activity.
5. General-license review, operational playbooks, certifications, end-use documentation and audit-ready transaction records.
6. Designation response and administrative-reconsideration petitions under 31 C.F.R. § 501.807, including questionnaires and supplemental evidence.
7. OFAC administrative subpoenas, pre-penalty notices, voluntary self-disclosures, enforcement submissions and settlement strategy.
8. Sanctions screening governance, list updates, fuzzy matching, beneficial ownership, false-positive and escalation procedures.
9. Charity and NGO controls for donors, implementing partners, procurement, beneficiaries, cash delivery and conflict-zone operations.
10. Cross-border coordination involving UK OFSI, European, Canadian or other sanctions regimes through appropriate local counsel.

Who we advise

We advise banks and payment companies handling blocked funds, attempted payments, ownership questions and license conditions. Fintechs and crypto exchanges engage us when sanctions screening intersects with wallet attribution, smart-contract exposure, mixers, decentralized services or cross-border customers. Companies use the team to assess counterparties, acquisitions, supply chains, insurance, shipping, trade documents and contractual rights following a listing.

Charities and NGOs seek advice when a designation affects a region, implementing partner, bank route or beneficiary community. We help them distinguish legal prohibitions from institutional risk appetite, examine available authorizations, and build a documented process that supports legitimate humanitarian activity. Designated individuals and organizations engage us to understand the administrative record, preserve evidence, prepare a reconsideration petition and respond to agency requests without making unsupported public claims.

Our approach

Our approach is evidence-led and authorization-specific. We establish what is prohibited, what may be authorized, what must be reported and what record will withstand later review.