OFAC Launches New Reconsideration Portal for Sanctions Delisting Petitions
On June 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the launch of a new online Reconsideration Portal for persons, entities, and property owners seeking removal from an OFAC-administered sanctions list. The Portal is intended to become the primary submission channel for administrative reconsideration requests, including petitions for removal from the Specially Designated Nationals and Blocked Persons List (“SDN List”).
The new Portal is designed to improve the efficiency of the delisting process by prompting petitioners to provide key information at the outset of a matter, rather than through multiple follow-up questionnaires that can delay OFAC’s review. OFAC has stated that the Portal will help the agency collect required and recommended information needed to conduct its reinvestigation of a delisting petition and determine whether the sanctions designation should remain in place.
In addition, sanctioned persons may use the Portal to request certain unclassified, non-privileged information underlying their sanctions determination. OFAC describes this material as a “courtesy document,” signaling that the disclosure is discretionary and will not necessarily include all information relied upon by the government, particularly where classified, privileged, law-enforcement-sensitive, or otherwise protected information is involved.
To accompany the launch, OFAC updated FAQ 897 (How can I ask OFAC to remove me or my organization from an OFAC sanctions list?), issued new FAQ 1261 (If my delisting petition requesting removal from an OFAC sanctions list is denied, may I petition for removal again?), and published two quick-reference guides: Best Practices for Delisting Petitions and What to Include in Your Delisting Petition.
OFAC frames these changes as part of a broader effort to increase transparency and efficiency in reconsideration proceedings. Although OFAC continues to accept delisting petitions by email for now, it strongly encourages petitioners to use the Portal for faster processing and has indicated that it is transitioning away from email submissions in the future. Petitioners and counsel should therefore expect the Portal—and the formatting, evidentiary, and procedural expectations reflected in OFAC’s new guidance—to become central to the delisting process going forward.
Practical Implications for Petitioners
The Reconsideration Portal is a welcome procedural development, but it should not be viewed as a simplified or purely administrative filing mechanism. Delisting petitions remain fact-intensive, legally complex, and often time-consuming. A successful petition typically requires a carefully developed record addressing the basis for designation, the applicable sanctions authority, any changed circumstances, and any legal or factual grounds demonstrating that continued designation is unwarranted. Petitioners should be prepared to submit complete, organized, and well-supported materials at the outset, because incomplete or inconsistent submissions may result in delays, additional information requests, or denial.
The ability to request a courtesy document may provide petitioners with additional insight into the non-classified and non-privileged information underlying a designation. However, the availability of that information does not alter the legal standard governing delisting or eliminate the government’s ability to rely on classified or otherwise protected information that may not be disclosed to the petitioner or counsel. As a result, petitioners should continue to anticipate information asymmetries and develop submissions that affirmatively address both the known record and plausible designation concerns.
Clients considering a delisting petition should also take note of OFAC’s updated guidance on refiling. Where a petition has previously been denied, any subsequent submission should present new evidence, new arguments, or materially changed circumstances. Repackaging the same arguments without a stronger factual or legal basis is unlikely to advance the matter and may undermine the credibility of the submission.
In light of these developments, early strategic planning remains essential. Petitioners should identify the applicable sanctions program and designation criteria, gather documentary support, assess whether changed circumstances or insufficient basis arguments are available, and ensure that all factual representations are accurate, consistent, and supported by evidence. Engaging experienced OFAC counsel remains important to framing the petition effectively, anticipating agency concerns, and aligning submissions with OFAC’s current expectations and procedural framework.
This advisory is provided for informational purposes only and does not constitute legal advice. Receipt of this advisory does not create an attorney-client relationship.
LBKM has a track record of successful delisting petitions resulting in removal from the SDN List. Our sanctions attorneys advise clients on a broad range of sanctions-related matters, including OFAC compliance, delisting petitions, enforcement actions, and criminal investigations. We understand the regulatory framework, evidentiary expectations, and strategic considerations involved in communicating complex facts to OFAC.
Read more about LBKM’s U.S. Sanctions practice, or visit our Sanctions Library for additional OFAC resources and updates.
Related: