OFAC Delisting

The formal petition process by which a designated individual or entity is removed from the SDN List.

TL;DR

TL;DR: Delisting is removal from the SDN List, which requires a formal petition to OFAC. It is not automatic and does not happen just because a screening tool flags a stale match.

How Delisting Works

A designated party can petition OFAC to be removed from the Specially Designated Nationals and Blocked Persons List. OFAC reviews the petition and decides whether the designation still holds. Removal changes the party's status from blocked to clear, but the process takes time and is not guaranteed.

Why List Currency Matters

Because designations are added and removed, a screening database must stay current. A counterparty that has been delisted but still appears in a stale list will be wrongly blocked, while one newly added to a stale list will be wrongly paid. sanctionsai.dev syncs its screening data hourly, covering 947 OFAC-listed wallets and 19,218 SDN names.

Agent Payment Relevance

An AI agent should trust the most recent list, not a cached snapshot. Under OFAC strict liability, intent is not required, so the agent's operator carries the risk if a stale list causes a mistake in either direction.

Practical Guidance

• Rely on hourly-synced data rather than manual exports.
• Treat a delisting as a change to ALLOW, but only after the list updates.
• Log which list version each screening decision used.