OFAC Updates Its Delisting Petition FAQs: What FAQ 897 and New FAQ 1261 Mean

When OFAC launched its Reconsideration Portal on June 29, 2026, the new filing system got most of the attention. A change with equal consequence got less. On the same day, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) rewrote its guidance on how the petition process actually works. It revised Frequently Asked Question (FAQ) 897, the main FAQ on requesting removal from an OFAC sanctions list, and published a new FAQ 1261 that answers a question petitioners ask constantly: if OFAC denies your delisting petition, can you try again?

For anyone on the Specially Designated Nationals and Blocked Persons List (SDN List), the two FAQs together are the most detailed account OFAC has published of what a delisting petition involves. Below, we lay out what they say and what they change for someone weighing an OFAC delisting petition.

What Changed on June 29, 2026

OFAC announced the FAQ updates alongside the portal. We covered the portal launch, the courtesy document, and the phase-out of email submissions in a separate article. This piece focuses on the guidance behind the portal:

• FAQ 897 was updated to walk through the full administrative reconsideration process, from filing through OFAC’s final determination, including the review timelines and the ground rules for status updates.
• FAQ 1261 is new. It confirms that a denial is not final, and it sets out the single condition on trying again.

Neither FAQ changes the governing law. A petition for administrative reconsideration still runs under 31 C.F.R. § 501.807. What the FAQs add is a clearer picture of how OFAC handles a petition after it arrives.

FAQ 897: How the OFAC Delisting Petition Process Works

FAQ 897 is where anyone asking how to get off an OFAC list should start. A person, organization, or property listed by OFAC, or that party’s authorized representative, can request removal through administrative reconsideration, the process OFAC uses to reassess whether the circumstances behind a designation still justify it. The updated FAQ sets the process out in stages.

Who the process is for

Administrative reconsideration is for people and entities that are actually on an OFAC list, or otherwise sanctioned. Two situations fall outside it:

• Mistaken identity is a different problem. If you have been confused with a sanctioned party because your name is a close match to a listed person, that is not a delisting matter. OFAC directs you to its Compliance Hotline instead.
• State Department designations follow a separate track. If your listing came from the Department of State rather than OFAC, the State Department runs its own review process for removal.

Filing and OFAC’s initial review

You submit a petition, also called a delisting petition or a reconsideration request, through OFAC’s Reconsideration Portal to ask that a person or property, such as a vessel, be removed from the SDN List or any other list OFAC maintains. Once it arrives, OFAC runs an initial review to confirm the submission contains the required information. If something required is missing, OFAC contacts the submitter to ask for it. If the petition looks complete, OFAC emails a petition identification number (a Case ID or Petition ID). OFAC says it aims to complete this initial review within seven to 10 business days.

That number is easy to misread. Seven to 10 business days is OFAC’s target for the intake review, not for a decision on the merits.

Reinvestigation, questionnaires, and status updates

After intake, OFAC reinvestigates the petition, and this is where timelines stretch. OFAC acknowledges that the process can be lengthy and that no two petitions move at the same pace. How long yours takes turns on factors like:

• How thorough and complete your initial submission was
• Whether OFAC needs to come back for more information
• Whether the petitioner has been forthcoming
• How much OFAC has to consult with other government agencies

If OFAC needs more, it sends questionnaires. Answering them fully, on time, and as instructed is one of the few things a petitioner controls once the case is in OFAC’s hands. To request a status update, OFAC tells you to follow the instructions in the email that assigned your Petition ID and to put “Status Update” in the subject line. It also warns that the volume of correspondence means it cannot reply to every request.

The determination

When OFAC has what it needs and finishes its review, it notifies you or your representative of the outcome by email. A petition is generally either granted or denied:

• Granted: the blocked person or property comes off the relevant list, and OFAC publishes notice of the delisting in the Federal Register.
• Denied: you can reapply using the same process, which is exactly what the new FAQ 1261 addresses.

FAQ 897 ends with a warning worth taking seriously. OFAC may deny petitions built on inconsistent, misleading, or false information. And knowingly and willfully making materially false statements, or concealing a material fact, in a submission to OFAC can carry criminal penalties. A delisting petition is a filing to a federal agency, and it deserves the same care as any other.

FAQ 1261: Can You Refile After OFAC Denies a Delisting Petition?

Yes. FAQ 1261 confirms that a denial is not the end of the matter. If OFAC denies your delisting petition, you can reapply through the same process you used the first time. One condition applies, and it is the whole point of the FAQ: you must present new arguments or evidence.

The condition matters. Refile without anything new, and OFAC may deny the second petition by pointing back to its earlier determination. A second petition has a real chance only when it gives OFAC a reason to decide differently: a fact that has changed, evidence that was missing from the record the first time, or an argument the first petition never made.

The clarification settles a long-running question. Petitioners have never been sure whether a denial was truly final. FAQ 1261 says it is not, while setting a clear bar for the second attempt. It also drives home why the first petition carries so much weight. The strongest position is a complete, well-documented case filed at the outset, not a first filing treated as a trial run.

What the Updated FAQs Mean for an SDN List Removal Strategy

Together, the two FAQs make the same point. OFAC rewards petitioners who put a complete and candid case on the table early, and it has little patience for thin or repetitive filings.

In practice, a few things matter:

• Treat the first petition as your best shot. The seven-to-10-business-day window is only for intake. The real work is the reinvestigation, and a complete first submission is what keeps that phase from dragging.
• Answer questionnaires quickly and fully. OFAC names the petitioner’s responsiveness as one of the factors that drives timing. Slow or partial answers cost you time you cannot get back.
• Do not refile reflexively. After a denial, a second petition needs genuinely new arguments or evidence. Repackaging the same record invites a denial by reference to the first decision.
• Get the facts right. Inconsistent or false statements can sink a petition and, in serious cases, expose the submitter to criminal liability.
• Remember what the FAQs do not change. Section 501.807 still imposes no deadline for OFAC to act. When a petition stalls without a decision, OFAC litigation can remain the only lever that forces the agency to move.

Frequently Asked Questions

How long does OFAC take to decide a delisting petition? OFAC aims to complete its initial review of a portal submission within seven to 10 business days, and it emails a Case ID or Petition ID once a petition looks complete. The decision on the merits takes much longer and varies case by case, depending on the thoroughness of the submission, OFAC’s need for more information, and the level of interagency consultation involved.

Can I reapply if OFAC denies my delisting petition? Yes. Under FAQ 1261, you can refile using the same process, but you must present new arguments or evidence. If you resubmit without anything new, OFAC may deny the second petition by referring back to its previous determination.

What if I was flagged by mistake because my name matches a sanctioned person? That is not a delisting matter. Administrative reconsideration is only for parties actually on an OFAC list. For a mistaken-identity or name-match issue, OFAC directs you to its Compliance Hotline.

Working With an OFAC Lawyer on a Delisting Petition

The updated FAQs make OFAC’s process more transparent, not easier. If anything, they show how much rides on the first filing: a complete record, candid statements, and arguments aimed at the actual basis for the designation. And because a second petition demands something new, the first attempt is not one to waste.

Sanctions Law Center represents individuals and companies seeking removal from the SDN List, from former executives of designated institutions to parties caught by mistaken identity or 50% Rule ownership chains. We handle the full delisting pathway: preparing a petition under 31 C.F.R. § 501.807, responding to OFAC’s questionnaires, engaging with OFAC’s Office of Global Targeting, and, where a petition stalls, taking the matter to federal court.

If you are on the SDN List or weighing a delisting petition, contact us to schedule a consultation with one of our OFAC lawyers.