Demystifying Delisting: A Guide to Seeking Removal From International Sanctions Lists


Issue 67 | March 2018

In this article, Barbara Linney* and Collmann Griffin, with Dr. Anna Bradshaw and Alice Kemp of Peters & Peters, discuss the different methods of challenging a sanctions list designation (listing) and seeking removal from the list (delisting) at the United Nations and in the EU, U.K., and U.S. "Over time, the United Nations, the European Union, and many of their member states, including the United States, the United Kingdom, and numerous other countries, have expanded their use of sanctions as a foreign policy tool, generating ever longer lists of individuals and entities subject to sanctions. Each jurisdiction has its own procedures for both adding names to the lists and addressing removal petitions," the authors wrote. "Adding to the complexities facing persons seeking removal from multiple lists, with 'Brexit' on the horizon, the United Kingdom is in the process of establishing its own separate mechanisms for persons seeking delisting from U.K. lists, and this process has shed light on the ongoing debate regarding the sufficiency of procedural rights protections available to targets of sanctions." The authors found the U.S. to be the most challenging jurisdiction for delisting and recommended a coordinated approach when seeking removal from multiple lists in order to achieve meaningful results.

*Former Miller & Chevalier attorney