OFAC has launched an online Reconsideration Portal to receive requests for reconsideration of SDN listings. The application process, previously conducted via email and involving repeated rounds of questions, has been centralized on the portal; essential information is now collected in a structured format at the time of application.
The portal is procedural. The substantive standard for reconsideration — demonstrating either that the listing is based on an insufficient basis or that there has been a substantial change in circumstances under 31 CFR 501.807 — remains unchanged.
OFAC also does not commit to any timeframe for a decision. In short: the application process has been simplified, but the threshold remains the same.
Comments are closed