In a 1 April 2021 article, Eric Lorber discussed the sanctions listing process and the likelihood of individuals or companies overturning them in court. According to Eric, “The reason for that is in large part that national security agencies—the State Department and OFAC [are afforded] broad discretion as to what falls under the purview of national security. And the courts give OFAC extremely broad deference … and unless there is really incredibly flimsy evidence that was being used to justify a designation, in almost every situation OFAC and the State Department would likely prevail on the listing.”

Read the full article in National Journal. Additional information can be explored through K2 Integrity’s expert insights: What the Biden Administration Brings on Sanctions and Applying Expensive Lessons Learned: The Importance of an Effective Sanctions Compliance Program.