Its been a year of trends at the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) and they just keep on trending. One such trend that I have written on several times is the large number of designations and removal of designations under the Foreign Narcotics Kingpin Designation (Kingpin Act) that has taken place this year. Well, OFAC kept right on removing former designees by releasing a whopping twenty seven (27) individuals and entities off of the list!

There is no telling why OFAC has been removing so many names off of the blocked persons list, however, I believe it is directly correlated with the large number of designations that have been handed down. It’s my personal beleif that OFAC is cracking down on drug cartels worldwide by casting a wider net. The bigger the net the less exact the designations. As such, I think designations are getting reviewed quicker and are based on less evidence therefore, making them easier to overturn.

The procedures for attempting to remove one’s name from the Kingpin List are found at 31 C.F.R. 501.807. Blocked persons are permitted to submit a petition for removal which offers arguments and evidence as to why that person should be removed. In addition, persons can offer remedial steps to be taken to ensure that they no longer engage in the activity that caused them to be placed on the list in the first place. Persons may also request a meeting with OFAC to discuss the petition, however, there is no right to a meeting. Once the information is gathered, OFAC will issue a written decision as to whether or not the person will be removed.

The full list of the twenty seven (27) individuals and entities removed can be found here.

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.