The United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) has removed a number of individuals from the Specially Designated Nationals (“SDN”) List recently. The individuals who were released from the list were originally designated under either the counter narcotics trafficking sanctions regulations or the Foreign Narcotics Kingpin Desigation Act (“Kingpin Act”). The individuals whose names were removed are as follows: Gladys Arbelaez Gallon, Salim Bechara Simanca, Jose Rolando Gomez Llanos Aispuro, Carlos Jose Ocampo Roman, and Alberto Alfredo Valencia Martinez.

While this news is encouraging, it also shows how long it takes for a designated party to be removed from the SDN List. For example, Jose Rolando Gomez Aispuro was designated in December of 2007. Sources have stated that he originally submitted a request for reconsideration shortly after that designation, however, it has taken OFAC nearly two and a half years to remove his name from the SDN list. During that time any assets he held that was under U.S. jurisdiction were blocked and U.S. persons were prohibited from engaging in transactions with him.

OFAC has designated hundreds of individuals and companies over the last year alone. In addition, there are thousands of designated persons on the SDN List. If you are on the SDN List, then you need to challenge that designation before anymore harm comes to your financial well being and your reputation. There are ways to do this, but you need to consult with legal counsel who has done this before and understands both the removal process and how OFAC operates.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 at 202-351-6161 or ferrari@ferrari-legal.com.