Practice 03
Delisting & Designation Challenges
A designation is not always the end of the matter. We assess — honestly — whether a listing can be removed or challenged, then pursue reconsideration or litigation before the EU General Court, the UK courts or under the US APA. We start with the odds, not a promise.
Applicable regime & authority
Remedy channels: an annulment action before the EU General Court (Article 263 TFEU), judicial review in the UK courts, administrative reconsideration before OFAC and review under the US Administrative Procedure Act, and the UN Ombudsperson for the relevant UN list.
Analysis
Full analysis is in preparation as part of the matrix build (Phase 2). This hub sets out the regime, the practical route and the FAQ; the detailed sub-topics — by authority, service and sector — link from here as they are published.
Practical steps
A decision-tree walkthrough of what to do, in order, will sit here. In the meantime, the FAQ below answers the questions clients ask first, and the Exposure Check gives a fast orientation.
Risk flags
Watch for secondary-sanctions reach, extraterritoriality across regimes, and fixed regulatory clocks. Where they apply, the time to act is measured in days, not weeks.
When to seek counsel
When a payment is held, a counterparty is newly designated, a deadline is running, or a position has to be defensible to a bank or regulator — a written assessment is the proportionate first step.
Cost & timeline framing
Most matters here start with a fixed-fee written position; larger engagements are scoped with a clear estimate. We do not charge success fees. See how we price.
Related practices
Sanctions Risk & Compliance
When exposure is uncertain, the first job is to see it clearly.
Read more →Related practiceLicensing & Authorizations
Some activity is permitted only with a licence.
Read more →Related practiceExport Controls & Dual-Use
Controlled goods, software and technology move only within the rules.
Read more →FAQ
Questions clients ask first.
Can you guarantee a delisting?
No — and be wary of anyone who does. We give a realistic, written view of the route and the odds before you spend on a petition or an action.
Where is a listing challenged?
It depends on the regime: reconsideration or APA review for OFAC, an annulment action before the EU General Court, judicial review in the UK, and the Ombudsperson for the relevant UN list. Each has its own standard and clock.
Do I need the statement of reasons first?
Usually, yes. The stated grounds define what has to be answered. Where they are unclear, the first step is to obtain and map them — which is what a feasibility opinion delivers.
Does time since designation matter?
It can affect both strategy and the evidential picture. Designations are reviewed and renewed, and the right moment to act is fact-specific rather than a fixed window.
Get a written position you can defend.
For designated persons and owned or controlled entities. A short call, then a fixed-fee written position — response within two hours in business hours.