How to Request Removal from an OFAC Sanctions List

• The listed name as it appears on an OFAC sanctions list. To ensure you enter the correct name, search for the relevant listing using OFAC's Sanctions List Search tool;
• The unique identification number (UID) found in the relevant listing in OFAC's Sanctions List Search tool;
  • Using the sanctions list search tool, you can find the UID by locating the entry for the sanctioned person or property. The UID will be the numeric string at the end of the web address (https://sanctionssearch.ofac.treas.gov/Details.aspx?id=#####) of the relevant entry following the text "id=" (e.g., "id=12345"). See FAQ 1031 for additional information on OFAC's sanctions list search tool UIDs.
• The date on which OFAC listed the relevant name;
  • You can find the date either by locating the press release that announced the relevant listing on OFAC's website (see the Recent Actions page on OFAC's website) or by searching the Federal Register. See FAQ 466 for more information on how to find the date a listing was added, updated, or removed from an OFAC list.

In addition, for listed individuals, include all of the following:

• full name (as it appears on an official government ID);
• proof of identity (such as a copy of an official government ID);
• all aliases;
• date of birth;
• place of birth;
• physical and mailing addresses;
• email addresses; and
• telephone numbers.

In addition, for listed entities or property, include all of the following:

• full official name (as it appears in government registration documents);
• official registration documentation (e.g., business license or aircraft/vessel registration number);
• all aliases;
• registration date;
• physical and mailing addresses;
• email addresses; and
• telephone numbers.

If a representative is petitioning on behalf of a listed person or property, OFAC requires:

• authorized representative's name and email address;
• proof of authorization to represent the listed person or property from the listed person (e.g., such as a power of attorney); and
• a description of the representative's relationship to the person or property.

Recommended, please include the following additional information:

• sources of income;
• current/past employment and professional activity;
• real property ownership;
• social media handles;
• contact and relationships with other persons and property listed on an OFAC sanctions list;
• bank account information, including virtual currency;
• ownership structures;
• a list of all past and current owners, operators, and managers; and
• websites.

Delisting petitions should include arguments and evidence that support one of two justifications for removal from OFAC's sanctions list:

1. that the circumstances resulting in the sanction no longer apply, i.e., a "change in circumstances"; or
2. that an insufficient basis exists for the sanction.

Change in Circumstances

OFAC considers change-in-circumstances arguments to be those demonstrating that, after the sanction was imposed, the sanctioned person took steps to remove the basis for the sanction or that the circumstances underlying the sanction otherwise changed. This may include resignation from a position held at the time of sanctioning; the liquidation, dissolution, or termination of a listed entity; or the cessation of all activity that poses a threat to the foreign policy, national security, or economy of the United States. Please note, transferring assets to other designated or blocked persons or other sham transactions may be viewed by OFAC as sanctionable conduct and/or that the circumstances underlying the sanction have not changed. Persons seeking to effect a change in circumstances by transferring assets or divesting from sanctioned entities to conduct due diligence on counterparties should coordinate with OFAC in advance, as these transactions could themselves trigger additional sanctions or expose third-party actors to possible sanctions.

• A sanctioned person may also propose remedial steps that they believe would negate the basis for the sanction. However, proposed remedial steps are not a substitute for arguments establishing a change in circumstances.

Insufficient Basis

OFAC considers insufficient-basis arguments to be those demonstrating that, at the time of the sanction, facts or circumstances existed showing that there was no basis for the sanction. This may include sanctions based on mistaken identity. It may also include sanctions on individuals who had resigned from relevant roles, or sanctions on entities that had dissolved, before the sanctions were imposed.

While OFAC expects many petitions to be submitted under only one of the two justifications (change in circumstance or insufficient basis), the Portal will allow arguments to be submitted under both justifications. Where appropriate, clearly state in any submitted arguments and evidence which justification applies.

To be successfully removed from an OFAC sanctions list, petitions involving persons or property sanctioned under multiple authorities will need to meet the criteria for removal from OFAC sanctions lists with respect to all authorities under which the person or property is sanctioned. For example, if an entity was designated pursuant to two Executive orders, a delisting petition would need to address relevant designation criteria for both Executive orders. The same applies if the entity was sanctioned under multiple designation criteria within a single sanctions authority—the delisting petition would need to address each designation criteria to be removed from an OFAC sanctions list.