What a long, strange trip it can be for SDNs.

On June 30, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the de-listing of Mohamed Daki, a Moroccan national formerly based in Europe. Daki’s de-listing followed more than a decade of criminal charges in Italian courts, his listing on the UN Security Council’s Al Qaida Sanctions Committee Sanctions List, and his designation for sanctions by U.S. authorities. While it is not clear as to how long Daki petitioned for his de-listing from OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”), Daki’s case evidences the immense hurdles that can exist for persons seeking rescission of their U.S. sanctions designation and the endurance that can be required to win one’s de-listing.

OFAC designated Mohamed Daki for sanctions on November 10, 2003 pursuant to Executive Order 13224. Daki had previously been arrested by Italian authorities in April 2003 for his alleged involvement in a host of terror plots, including connection to the September 11 attacks in New York and Washington, D.C. Specifically, Daki was alleged to have recruited persons from Europe to launch suicide attacks against U.S. troops in Iraq, according to a Washington Post report from 2004, and to have consorted with certain of the September 11 hijackers. While based in Hamburg, German authorities placed Daki under constant surveillance, though they were unable to put together enough facts to prosecute him there.

Daki beat most of the charges in Italian courts, however. In January 2004, an Italian court ruled that Daki could not be held for supporting terrorism, as his recruits sent to Iraq were “guerrillas and not terrorists.” Daki was found guilty of providing false documents to migrants, however, but was released for time served. This episode gave rise to a Washington Post profile in March 2005, highlighting the difficulties European courts were having prosecuting alleged terrorists and their supporters. Later, Daki was deported from Italy to Morocco soon after final appeal of the Italian court’s decision. Few public reports provide information on his activities in Morocco since the time of deportation.

We do know that Daki won rescission of his listing on the UN Security Council’s Al-Qaida Sanctions Committee’s Sanctions List on August 19, 2013 –- almost a decade from the date of his initial listing. Most likely, that followed Daki’s petition to the Al-Qaida Sanctions Committee to remove his name from the sanctions list – a challenge to the basis for his designation that likely predated his challenge to his EO 13224 OFAC designation. The Al-Qaida Sanctions Committee had first added Daki to its sanctions list on November 12, 2003. That meant that Daki was subject to a globally-imposed asset freeze for a decade.

Last week, Daki hurdled the final barrier – winning rescission of his designation from OFAC’s SDN List and the lifting of U.S. blocking sanctions. Presumably, OFAC’s action followed Daki’s request for administrative reconsideration of his designation as a Specially Designated Global Terrorist (“SDGT”), though OFAC could have rescinded the designation on its own cognizance.

Regardless, Daki remained on OFAC’s SDN List for close to 13 years.  That is no insignificant amount of time, particularly considering the immense challenges that come with such a designation.  For Daki, though, thanks to the criminal charges and his UN sanctions listing, his road to redemption has certainly been eventful.