Getting Removed From the Specially Designated Nationals (SDN) List
The United States government, acting through the Department of Treasury’s Office of Foreign Assets Control (OFAC), will target and “designate” an individual or business based on foreign policy and national security concerns. Collectively, the individuals and businesses are called “Specially Designated Nationals” or "SDNs."
The designation can mean public humiliation and financial ruin. This form of economic warfare blocks (freezes) the designee's assets, seeks to limit its international trade and cut off all financial transactions that are subject to U.S. domestic or extraterritorial jurisdiction.
It is an economic death penalty and can last a lifetime.
OFAC maintains an SDN list of thousands names of individuals and businesses that have been designated based on subject matters such as international narcotics trafficking, money laundering, and international terrorism. Designations are also made for reasons that are country specific such as the Democratic Republic of Congo (DRC), Belarus, and Myanmar. The SDN list is frequently updated.
We offer representation in SDN removal. We challenge OFAC's designation through the use of legal challenges and seek to have our clients' names and/or businesses removed from the OFAC SDN list. The firm has been successful with past removals. It is currently handling a number of these matters and is known for fighting vigorously for our clients.
Our Washington, DC office is located 1 block from OFAC.
Douglas McNabb is an internationally recognized expert in OFAC SDN Sanctions Removal and is the author of OFAC SDN Sanctions Removal Blog.
Washington, DC 1455 Pennsylvania Ave, NW Suite 400 - Washington, DC 20004 +1 202.351.6161
Houston, TX 22136 Westheimer Parkway Suite 521 - Katy, TX 77450 +1 713.237.0011
Country-Based Designation Lists - US Department of Treasury maintains specially designated national (SDN) lists that are specific to countries covered within national sanctions lists. These SDN lists evolve as national sanctions are put into place by the US Government.
Terrorism (SDT, SDGT and FTO) – sanctions against designated individuals and businesses that seek to disrupt the Middle East peace process; against the governments of countries that support international terrorism; and against foreign terrorist organizations.
Narcotics Traffickers (SDNT (Colombia) and SDNTK (Kingpin)) - sanctions against designated individuals and businesses that are considered to be significant foreign narcotics traffickers.
Diamond Trading – sanctions against countries that are not participants in the Kimberly Process Certification Scheme (KPCS) for rough diamonds.
TRANSNATIONAL CRIMINAL ORGANIZATIONS
Transnational Criminal Organizations (TCO) – sanctions specific individuals and entities determined to be significant transnational criminal organizations or to have provided material support for, or to be owned or controlled by, or to have acted on behalf of, such organizations. Additionally, the property and interests in property of an entity that is 50% or more owned, directly or indirectly, by a person on the SDN list are also blocked.
WEAPONS OF MASS DESTRUCTION
Weapons of Mass Destruction Proliferators (NPWMD) – two distinct sanction programs directed against designated businesses, countries and individuals that have engaged in proliferation-related activities; another sanction program that blocks U.S. attachment and garnishment orders against a specific set of Russian Federation assets used to implement the HEV Agreements.