"Sanctions Reconsideration Portal" for OFAC Petition Process

The Treasury’s Office of Foreign Assets Control (OFAC) has issued a notice requesting public comment on a proposed electronic Sanctions Reconsideration Portal. The initiative seeks to streamline administrative reconsideration requests submitted under OFAC’s Reporting, Procedures and Penalties Regulations (31 CFR § 501.807) by sanctioned individuals or entities.

As outlined in the Federal Register notice, the new portal would provide a voluntary online mechanism for sanctioned parties and their authorized representatives to submit petitions for delisting from OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), as well as other sanctions lists. The proposed change is part of OFAC’s effort to reduce paperwork burdens.

Service Standards

OFAC Currently has a licensing function; the new portal can be expected to follow that model, though service standards may prove disappointing.

Sanctions attorney Erich Ferrari notes in a recent LinkedIn post that "OFAC Licensing's new automated message in response to license applications reads as follows:

"OFAC will contact you when a Case ID is assigned to your application. Due to high volume, it may take up to 60 days [(!)] for OFAC to issue a Case ID number for your application. If you must contact OFAC sooner regarding your application, please have your Reference ID [(XXXXX)] available. Please note that we are unable to provide a status update until a Case ID is assigned."

While "up to 60 days" for a case number is not great news, this greater level of transparency from OFAC will (hopefully) help manage client expectations.

The New Portal

OFAC anticipates approximately 300 respondents annually, each spending an estimated three hours to complete a petition via the portal. The total projected annual burden is 900 hours. 

The agency emphasizes that the portal will not alter existing procedures or legal standards for reconsideration but aims to enhance administrative efficiency and data collection. Petitioners would be prompted to provide supporting documentation and narrative justifications electronically, in a format designed to improve processing timelines and transparency.

OFAC invites comments from the public and other federal agencies by August 25, 2025, on issues including:
• The necessity and utility of the proposed information collection;
• The accuracy of burden estimates;
• Suggestions for improving data quality and minimizing respondent burden;
• Ideas for leveraging automated technology; and
• Any associated costs for compliance.

Comments may be submitted electronically via www.regulations.gov (referencing Docket Number OFAC-2025-0001 and OMB Control Number 1505-0164) or by email to OFACreport@treasury.gov with subject line: “Attn: Request for Comments on Sanctions Reconsideration Portal (Reporting, Procedures and Penalties Regulations)”.

Office of Foreign Assets Control Reporting, Procedures and Penalties Regulations Sanctions Reconsideration Portal