Sanctions regimes administered by the U.S. Office of Foreign Assets Control (OFAC) — as well as parallel regimes enforced by the European Union, the United Kingdom, Canada, and other jurisdictions — have expanded significantly in recent years. Designations arising from the conflict in Ukraine, North Korea, Cuba, longstanding and recent programs targeting Iran, and evolving programs relating to Venezuela, and newer measures directed at entities with ties to China and other countries have created a complex, overlapping web of restrictions that affect businesses, individuals, and transactions across the globe.
Being designated — or simply having ties to a designated party — can have sweeping consequences, including: frozen assets, prohibitions on doing business in the United States, restrictions on travel, and the inability to obtain legal representation from firms that have made categorical decisions to avoid sanctioned clients. Even parties who are not themselves designated can find their transactions and operations significantly complicated by the sanctions exposure of counterparties or business partners.
Ford O’Brien Landy LLP represents individuals and entities navigating sanctions-related challenges. Our work in this area includes:
Sanctions obligations also intersect significantly with digital asset activity, including AML compliance and OFAC requirements for cryptocurrency exchanges and platforms. For a more detailed discussion of our work in that area, see our Digital Asset Compliance and Regulatory Defense page.
Contact us to learn how we can help.
U.S. economic sanctions are legal restrictions that prohibit or limit transactions involving certain countries, governments, entities, and individuals, often to advance national security and foreign policy goals. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers most federal sanctions programs and maintains the Specially Designated Nationals and Blocked Persons List (the “SDN List”). The State Department also plays a role in designations under certain programs, and the Department of Justice can bring criminal charges for willful sanctions violations. Because sanctions matters can carry both civil penalties and criminal exposure, Ford O’Brien Landy approaches them with an eye toward a variety of potential consequences.
Consult counsel experienced in sanctions matters as soon as possible. When assets are blocked, they are frozen in place, and banks or other institutions holding them generally cannot release them without authorization from OFAC. Counsel can determine why the assets were blocked, whether the blocking resulted from a designation or a mistaken match, and what avenues for relief are available. Depending on the circumstances, those avenues may include requesting the release of assets blocked in error, applying to OFAC for a license authorizing specific transactions, or pursuing removal from the SDN List. The Firm helps individuals and businesses evaluate their options and pursue the strategy best suited to their situation.
Yes. Designated individuals and entities may petition OFAC for removal from the SDN List, typically by showing that the basis for the designation no longer exists, that circumstances have changed, or that the designation was mistaken. The process often involves submitting evidence and responding to detailed questions from OFAC, and it can take considerable time. In some cases, a designation may also be challenged in federal court, although courts generally give the government significant deference. Ford O’Brien Landy advocates for clients seeking delisting, crafting submissions that address the specific basis for the designation and the government’s concerns.
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