OFAC Launches a Reconsideration Portal for SDN List Removal

On June 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) launched a new online Reconsideration Portal for people and companies asking to be removed from an OFAC sanctions list. For anyone on the Specially Designated Nationals and Blocked Persons List (SDN List), the portal reworks how petitions get filed. It also opens a formal channel for requesting the evidence behind a designation, and it signals that OFAC means to retire email submissions for good.

Here is what the portal changes, what it leaves alone, and what it means if you are trying to get off the SDN List.

What OFAC Announced on June 29, 2026

OFAC’s announcement covered several connected changes to the petition for administrative reconsideration process, the formal route for asking OFAC to remove a name from a sanctions list. The agency describes the new Reconsideration Portal as a way to “streamline the petitions process by guiding submitters to provide necessary information upfront, rather than through a series of questionnaire/answer exchanges that can delay efficient adjudication of a delisting petition.”

Alongside the portal, OFAC said it is:

• Updating Frequently Asked Question (FAQ) 897 and adding a new FAQ 1261 on the petition process.
• Publishing two quick-reference guides, Delisting Petitions Best Practices and What to Include in a Delisting Petition.
• Letting listed persons request a “courtesy document” through the portal, meaning certain unclassified, non-privileged information underlying their designation.

OFAC also made clear where this is headed. It “strongly encourages” petitioners to file through the portal, both for faster processing and because it plans to move away from email submissions in the future.

What Is the Reconsideration Portal?

The Reconsideration Portal is an online intake system for delisting requests. Rather than email a petition and then field a string of follow-up questionnaires, a petitioner works through the portal, which prompts for the information OFAC needs to open and evaluate a case.

It targets a familiar bottleneck. Under 31 C.F.R. § 501.807, OFAC’s reconsideration procedure lets a designated party present arguments and evidence for why the listing should come off, after which OFAC can send written questions, ask for more documents, or arrange a meeting before it decides. That back-and-forth has a way of dragging cases out over months or years, one round of questions at a time. Front-loading the key information is OFAC’s attempt to shorten the cycle.

Two points are easy to get wrong. The portal changes how you file, not the legal standard OFAC applies; the agency still weighs whether the facts and circumstances that led to the designation have changed. And § 501.807 sets no deadline for OFAC to act, so filing through the portal does not put your petition on a clock.

The Courtesy Document: Seeing the Evidence Behind Your Designation

For most petitioners, the courtesy document is the part of the announcement to focus on. When OFAC designates a person or company, its reasons go into an administrative record, but that record does not come to you automatically. The courtesy document is how a listed party can request the unclassified, non-privileged information OFAC relied on in adding them to the list.

A delisting petition is only as strong as its answer to the actual basis for the designation. If you do not know exactly why OFAC listed you, you are arguing against a target you cannot see. The courtesy document narrows that gap.

It is not full disclosure. OFAC can redact material that is classified, law enforcement sensitive, or commercially sensitive, so parts of the record may stay hidden. Even so, getting the courtesy document and reading it closely is one of the first moves in building a petition that answers OFAC’s real concerns instead of guessing at them.

Email Submissions Are on the Way Out

OFAC was blunt about its plan to phase out email submissions. Both routes work for now, but the agency is steering petitioners toward the portal and has said the email option will not stick around.

If you have a petition already moving by email, or you are drafting one now, this is a reason to look at how you are filing and to plan around the portal from here on. Anyone advising clients on SDN List removal should treat the portal as the default path.

How the Delisting Petition Process Works

If the process is new to you, here is the basic shape of an OFAC delisting petition, and where the portal fits in.

1. Request a courtesy document (optional, but often wise). Ask OFAC for the unclassified information behind the designation so your petition can address the real basis for the listing.
2. File the petition through the portal. Lay out who you are, why the designation no longer fits the facts, and the evidence for removal. This is where OFAC’s new upfront model wants the substance to live.
3. Respond to OFAC’s questions. OFAC’s Office of Global Targeting reviews the petition and may send written questions or ask for more documents under § 501.807. A strong front-loaded submission aims to keep this phase short.
4. OFAC decides. OFAC can lift the designation, leave it in place, or, in some cases, resolve the matter after further engagement. There is no fixed timeline.

Successful petitions almost always turn on evidence. OFAC removes a name when the record shows the reasons for the designation no longer hold, say because a person has left a role at a sanctioned company, cut ties with a sanctioned government, or was swept in by mistaken identity or a 50% Rule ownership chain that no longer applies.

What the Portal Does and Does Not Change

What changes:

• Petitions and courtesy-document requests now run through a single online system.
• OFAC asks for key information at the outset instead of pulling it out through rounds of questionnaires.
• There is a defined channel for requesting the unclassified basis of a designation.
• Email submission is being phased out.

What stays the same:

• The governing regulation is still 31 C.F.R. § 501.807.
• OFAC still weighs whether the facts behind the designation have changed.
• No statutory or regulatory deadline forces OFAC to act.
• A weak or incomplete petition is still a weak petition, however it is filed.

Hold onto that last point. A cleaner intake form does not lower OFAC’s evidentiary bar. If anything, an upfront model favors petitioners who show up with a complete, well-documented case, and it punishes those who file thin and hope to patch the gaps later.

Practical Takeaways for SDN-Listed Individuals and Companies

• File through the portal. It is OFAC’s preferred channel now, and email is on its way out.
• Request the courtesy document early. Read what OFAC will disclose before you finalize your arguments, so your petition answers the real basis for the listing.
• Front-load your evidence. The portal is built around complete first submissions. Treat the initial filing as your strongest argument, not a placeholder.
• Do not mistake the portal for a deadline. OFAC still has no obligation to act within any set time, so persistence, and sometimes OFAC litigation, stays part of the picture for stalled petitions.

Frequently Asked Questions

Does the Reconsideration Portal make it easier to get off the SDN List? It makes filing more organized and gives you a formal way to request the information behind your designation. It does not change the legal standard OFAC applies, and it does not guarantee a faster decision. The strength of your evidence still decides the outcome.

What is a courtesy document? It is a document OFAC will prepare on request that identifies the unclassified, non-privileged information underlying your designation. Some material may be redacted if it is classified, law enforcement sensitive, or commercially sensitive.

Can I still file a delisting petition by email? For now, yes. But OFAC has said it plans to move away from email submissions and is directing petitioners to the portal, so filing through the portal is the safer choice going forward.

Working With an OFAC Lawyer on a Delisting Petition

The Reconsideration Portal is a genuine improvement, and petitioners should find the process more transparent and quicker for it. What it does not touch is the hard part: building a factual record strong enough to persuade OFAC to reverse a designation. That work — reading the courtesy document, pinning down the precise basis for the listing, and assembling the evidence that undercuts it — is where petitions succeed or fail.

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: requesting a courtesy document, preparing a petition under 31 C.F.R. § 501.807, 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.