Sanctions Explained

How sanctions delisting works: OFAC, UK, EU and UN

Last checked: 20 October 2026 · How to check

Each sanctions authority has its own removal route 1,5 6,9. For OFAC, a listed person files a reconsideration petition under 31 CFR 501.807 1. In the UK, a designated person asks the FCDO to vary or revoke the designation and can then go to the High Court 3,4 5. In the EU, a listed person asks the Council to reconsider and can go to the General Court 6. For UN lists, requests go to the Focal Point for De-listing or, for the ISIL (Da'esh) and Al-Qaida list, the Ombudsperson 9,10.
US (OFAC)
Reconsideration petition under 31 CFR 501.807 1
UK
Review request to the FCDO under section 23 of SAMLA 2018 4,5
EU
Request to the Council, and a case at the General Court 6
UN, most lists
Focal Point for De-listing 9
UN, ISIL (Da'esh) and Al-Qaida list
Office of the Ombudsperson 10
Fees
None stated in OFAC FAQs 897 and 1261 2

United States: OFAC reconsideration

Under 31 CFR 501.807, a sanctioned person can ask OFAC to remove a person or property from the SDN List or another OFAC list 1. The petitioner can argue that there is an insufficient basis for the sanction or that the circumstances no longer apply 1. The petition can propose remedial steps, such as a corporate reorganization or resigning from a blocked entity 1.

The sources differ on how to file. The regulation, as published on eCFR up to date as of 16 October 2026, says requests go by email to [email protected] 1. OFAC FAQ 897, read on 20 October 2026, directs petitioners to OFAC's Reconsideration Portal 2. OFAC says it aims to do its initial review of portal submissions within seven to 10 business days and that processing can be lengthy 2.

OFAC may ask for more information and may send questionnaires 1,2. It gives a written decision 1. A granted delisting is published in the Federal Register 2. A denied petitioner can file again with new arguments or evidence 2.

United Kingdom: FCDO review and court

Under section 23 of the Sanctions and Anti-Money Laundering Act 2018, a designated person may ask the Minister to vary or revoke a designation 3. After one request, another is allowed only if it raises a significant matter not considered before 3.

The FCDO asks for a completed Sanctions Review Request Form, sent to [email protected], with a postal option in London 5. It says it decides as soon as reasonably practicable and that it is not possible to give exact timelines 5.

Under section 38, the person can apply to the High Court, or the Court of Session in Scotland, to set aside the decision 4. The court applies judicial review principles 4. A person on a UN list can ask the UK to use its best endeavours to secure removal from that list 5.

European Union: Council and General Court

The Council says a listed person or entity can ask it to reconsider the listing, with supporting documents, by writing to the Council's General Secretariat 6. The person can bring a case before the General Court 6.

Article 275 of the Treaty on the Functioning of the European Union gives the Court jurisdiction to review the legality of Council decisions with restrictive measures against natural or legal persons 8. Such cases follow Article 263, which sets a two-month time limit from publication, notification or the day the applicant learned of the measure 7,8.

The Council says EU autonomous Council decisions usually apply for 12 months and mixed provisions are reviewed at least once every 12 months 6.

United Nations: Focal Point and Ombudsperson

The Focal Point for De-listing was set up under resolution 1730 (2006) 9. It handles requests for all Security Council sanctions lists other than the ISIL (Da'esh) and Al-Qaida list 9. A listed person can apply directly, through a representative, or through the state of residence or citizenship 9.

The Office of the Ombudsperson was set up under resolution 1904 (2009) and handles the ISIL (Da'esh) and Al-Qaida list 10. The Ombudsperson gathers information, reports to the committee with a recommendation, and passes the committee's decision to the petitioner 10. Its mandate expires on 17 June 2027 10.

Focal Point stageTime set by the UN
Information gathering4 months, extendable by up to 2 months 9
Dialogue with the petitioner2 months, extendable by up to 2 months 9
Committee decisionAbout 2 months 9

Compared

ListWhere to applyCourt route
OFACOFAC Reconsideration Portal or email under 31 CFR 501.807 1,2Not set out in 31 CFR 501.807 1
UKFCDO, by review request form 5High Court or Court of Session 4
EUCouncil General Secretariat 6General Court, within two months 6,7
UNFocal Point or Ombudsperson 9,10No court route described on the UN pages 9,10

Common questions

Do I need a lawyer to ask OFAC for delisting?

OFAC FAQs 897 and 1261 do not say a lawyer is required. They allow an authorized representative to file 2.

What if I only share a name with a listed person?

That is not a delisting matter. OFAC directs close name matches to its Compliance Hotline 2.

Is there a deadline for a UK decision?

No fixed one. The FCDO says it decides as soon as reasonably practicable and that it is not possible to give exact timelines 5.

How long does a UN Focal Point review take?

The UN sets about 4 months for information, 2 months for dialogue and about 2 months for the decision, with possible extensions 9.

Can I apply again after a refusal?

OFAC accepts a new petition with new arguments or evidence 2. In the UK, a new request must raise a significant matter not considered before 3.

Rules and fees change. Check the official site linked above before you apply or pay. Spotted an error? Email [email protected] with the official link.

Sources

  1. eCFR: 31 CFR 501.807, Procedures governing delisting (up to date as of 16 October 2026)
  2. OFAC: Frequently Asked Questions, Specially Designated Nationals and the SDN List, FAQs 897 and 1261 (accessed 20 October 2026)
  3. legislation.gov.uk: Sanctions and Anti-Money Laundering Act 2018, section 23, Right to request variation or revocation of designation
  4. legislation.gov.uk: Sanctions and Anti-Money Laundering Act 2018, section 38, Court review of decisions
  5. GOV.UK, FCDO: Making a sanctions challenge, how to seek variation or revocation of a sanctions designation (updated 2 February 2023)
  6. Council of the EU: How the EU adopts and reviews sanctions (last reviewed 12 April 2024)
  7. EUR-Lex: Treaty on the Functioning of the European Union, Article 263
  8. EUR-Lex: Treaty on the Functioning of the European Union, Article 275
  9. United Nations Security Council: Focal Point for De-listing (accessed 20 October 2026)
  10. United Nations Security Council: Office of the Ombudsperson to the ISIL (Da'esh) and Al-Qaida Sanctions Committee (accessed 20 October 2026)

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