Bachir El Nakib ACAMS Faculty Mmember
Specially Designated Nationals And Blocked Persons List (SDN) Human Readable Lists. ... Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked and U.S. persons are generally prohibited from dealing with them.
Who List Specially Designated Nationals?
The Office of Foreign Assets Control (OFAC) of the Department of the Treasury administers and enforces economic and trade sanctions against targeted foreign countries and regimes, terrorists, international narcotics traffickers, persons engaged in the proliferation of weapons of mass destruction, and others who present ...
Which organization has the right to unfreeze the assets of Specially Designated Nationals?
Washington, D.C. The Office of Foreign Assets Control (OFAC) is a financial intelligence and enforcement agency of the U.S. Treasury Department.
The petition may include background facts, legal and policy arguments, and calculated analysis on why the designated individual or company should be removed from the SDN List.
OFAC’s response time to the petition for removal is not fast. OFAC may take 6-30 months to respond to any petition or request related to your removal from the SDN List.
For example, if OFAC alleges that you own or control a football team involved in money laundering and drug trafficking, and you are able to provide satisfactory information to show that you in fact did not have ownership or control over the football team, then you may be removed from the SDN List. Please note that successfully arguing this does not start and end with simply asserting that OFAC has made a mistake. You or your company needs to have satisfactory accompanying documentation and evidence that the allegations OFAC has made underlying the reason you were placed on the SDN List is incorrect.
A change in circumstance argument may show that you or your company no longer engages in the activities that you were sanctioned for previously. One can show this by substantiating a lack of ability to further engage in such activity and that you do not intend to continue to engage in the activity that OFAC used to place you on the SDN List. The addition of compliance policies, removal of corporate officers engaged in the activity, or corporate restructuring may further advance your change of circumstances argument.
For example, if OFAC alleges that you own or control a futbol team that engaged in money laundering and drug trafficking, you may show that the futbol team entity has dissolved and is not in business anymore. You may resign from the futbol team or institute policies that would prevent the illicit activity from continuing to take place in the futbol team’s corporate organization. You may divest from any investments or financial accounts that were involved in the matters that concern OFAC. You may also hold those who engaged in the activities responsible and dismiss them from their positions. Some or a combination of these changes may substantially increase the chance that your change in circumstances argument is successful in removing you or your futbol team from the SDN List. Most important for your Petition for Removal is accurately explaining and providing necessary documenting demonstrating the changes that were made that would decrease concern that you or your company would continue to engage in the activity in the future.
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