What is delisting (sanctions)?
A party you blocked last year has been removed from the list. Delisting is that removal by the designating authority: from the effective date the prohibitions no longer apply and frozen assets are released, subject to the authority's conditions.
Delisting follows a successful petition, a change in the underlying situation, a court annulment or the expiry of a regime, and each authority runs its own route. OFAC accepts removal petitions, the UN operates a Focal Point and an Ombudsperson for the ISIL and Al-Qaida regime, and the EU conducts periodic reviews with challenges available before the Court of Justice. The misunderstanding that causes real problems in screening is retrospective: delisting is forward-looking, so a transaction blocked while the party was designated was blocked correctly.
What this workflow covers
SCOPE- List ingestion has to handle removals as well as additions, or monitoring keeps alerting on a record the authority deleted.
- A shipping company that shows OFAC its designated shareholder has divested drops out of the next SDN file.
- Partial delisting is normal: removed by one authority, still designated by another, which makes a single-list result look inconsistent with reality.
- Delisting is not an acquittal, unless a court says so, and it does not erase the history of the designation.
Compliance glossary
TERMS- Removal petition
- A written request to a sanctions authority asking it to reconsider and revoke a designation.
- Periodic review
- A scheduled reassessment by the authority of whether a designation still meets the listing criteria.
Authoritative references
SOURCES- 01Filing a Petition for Removal from an OFAC List
U.S. Department of the Treasury — OFAC
- 02The UK Sanctions List
Foreign, Commonwealth & Development Office
Frequently asked questions
Q&A- How does a client get off the OFAC SDN List?
- By filing a petition for removal setting out why the designation is no longer appropriate, for example that the basis was factually mistaken, that the conduct has stopped, or that ownership has changed. OFAC can ask for additional information before it decides.
- How long does delisting take?
- There is no timetable, and cases commonly run for many months or longer. The authority controls the pace and can request further evidence at any point, so treat any promised timeline with suspicion.
- Do we go back and correct the old screening records?
- No, and you should not. Historical evidence has to reflect the list content on the screening date; amending a past record to match a later list state destroys the audit value of the file you were keeping it for.