DC Federal Litigation Federal Practice · FOIA · Sanctions · Trademark

OFAC Delisting — Paid Consultation on Removal From the SDN List

A paid consultation with Sherrod Seward, Esq. on a designation, a pending reconsideration petition, or a petition that has been sitting for years.

Consultation fee $500 — not payable yet on a sanctions matter The $500 is the fee for the consultation itself and for the written summary that follows it. It is not a retainer, and it does not include drafting or filing a FOIA request, an administrative appeal, a licence application, a delisting petition, a federal court complaint, a trademark application, a response to a USPTO office action, or a post-registration maintenance filing - each of those is separately scoped and separately quoted. Government, agency and court filing fees, any agency search, review or duplication fees, and any USPTO filing fees, are not included and are payable to the government, not to this office. Government, agency and court filing fees, and any agency search, review or duplication fees, are separate from this fee and are payable to the government.

A designation is a continuing status rather than a penalty that expires, and it does not lift on its own. OFAC's regulations provide a route to ask for removal, and the petition is won or lost on what it establishes about the basis for the listing. You will leave the call knowing what your petition would have to show, what the realistic timeline looks like, and what options exist when a petition has been pending far longer than it should.

Why this page does not ask you to pay

Before this office can accept a consultation fee on a sanctions matter, it must screen the prospective client and, separately, whoever would be paying. Where a person or entity is blocked, providing legal services and receiving payment for them are two different questions under the sanctions regulations, and the answer to the first does not answer the second. So there is no payment link on this page. Send the enquiry, this office will run the screening, and if a fee can lawfully be accepted you will be told what it is and how to pay it. If it cannot, you will be told that instead.

Sending this form does not engage this office and does not create an attorney-client relationship. Nothing here is an offer to represent any person or entity, and nothing here should be read as a statement that this office is authorised to act for, or to accept payment from, any particular person.

Prefer to speak to someone first? +1 (202) 999-3631

Request a consultation

Six fields. About a minute.

USCIS, the State Department, the EPA, the FBI, OFAC — or "not sure" if that is the honest answer.

Bring the call one of these

  • You or your company have been designated and need to understand the route off the list.
  • A reconsideration petition has been pending for years with no decision.
  • You are caught by ownership rather than by being listed yourself.
  • Your bank has frozen or rejected transactions and will not explain why.
  • You need to know whether this office can act for you at all before anything else.

What a reconsideration petition has to do

31 C.F.R. 501.807 sets out the procedures governing delisting from the Specially Designated Nationals and Blocked Persons List and from the other lists OFAC maintains. A blocked person may submit arguments or evidence that an insufficient basis exists for the designation, or that the circumstances that produced it no longer apply, and may propose remedial steps — a corporate reorganisation, a resignation from a position, a severing of the relationship the designation rests on. The filing mechanics have changed recently and are still settling, so they are confirmed against the agency's current guidance at the time of each consultation rather than assumed.

This office has been the plaintiff, not only the drafter

Law Offices of Sherrod Seward, PLLC v. U.S. Citizenship and Immigration Services

No. 3:25-cv-00057 (W.D.N.C.), filed January 2025

This office has been the plaintiff in a Freedom of Information Act case, not only the drafter of the request. When an agency declined to produce records, the firm filed suit in its own name under 5 U.S.C. 552 to compel production.

A pending matter is described here as a fact about this office's own experience. It is not a result, it does not predict anything about any other case, and every case is decided on its own record. Prior results do not guarantee a similar outcome.

How it runs

  1. Send the enquiryThe form below. It takes about a minute and it asks for nothing sensitive.
  2. ScreeningThis office screens the prospective client and, separately, whoever would pay. On a sanctions matter that has to happen before a fee can be accepted.
  3. You are told where you standEither what the consultation costs and how to pay it, or that a fee cannot lawfully be accepted here. You will be told plainly which.
  4. The consultationThe call itself, followed by a written summary of what was decided and the dates that govern it.

Watch first

Questions people actually ask

What do I actually get for the fee?

The $500 is the fee for the consultation itself and for the written summary that follows it. It is not a retainer, and it does not include drafting or filing a FOIA request, an administrative appeal, a licence application, a delisting petition, a federal court complaint, a trademark application, a response to a USPTO office action, or a post-registration maintenance filing - each of those is separately scoped and separately quoted. Government, agency and court filing fees, any agency search, review or duplication fees, and any USPTO filing fees, are not included and are payable to the government, not to this office.

Is this legal advice?

The consultation is. This page is not — it is general information about federal practice, and reading it creates no relationship with this office. Sending this form does not create an attorney-client relationship. No attorney-client relationship is formed until this office and you have signed a written engagement agreement.

Can you tell me what my chances are?

You will get a candid assessment of what your record supports and where it is thin, which is the useful version of that question. What you will not get is a percentage. Every matter is decided on its own record by a government officer or a judge, and prior results do not guarantee a similar outcome.

What happens if you cannot help?

You will be told so on the call, and told where the matter actually belongs. That happens often enough to be worth saying out loud.

I am not on the list, but my company is treated as if it is. Why?

Almost certainly ownership. OFAC treats an entity that is owned, in the aggregate, 50 percent or more by one or more blocked persons as blocked itself, whether or not it is separately named on the list. Aggregation across several blocked owners is what catches people out, because no single owner appears to cross the line. Working out whether that is what has happened to you is a factual exercise and part of the call.

Why is there no payment button on this page?

Because on a sanctions matter this office has to screen the prospective client and, separately, whoever would pay, before it can accept a fee. Where a person is blocked, providing legal services and receiving payment for them are two different questions under the regulations, and an authorisation for the first is not an authorisation for the second. Taking money before that is settled would be this office's problem, not yours, and the answer is to do the screening first.

Send the enquiry and this office will screen it before anything else happens.

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Consultation on a sanctions matterScreened before any fee
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