I read government filings at night. I know. (at least I don’t see dead people)
The house finally goes quiet around ten. Boys are asleep, and I get an hour where nobody needs anything from me. Some women watch television. I read Treasury reports and drink coffee I have no business drinking at that hour. (And yes I still sleep).
A few weeks ago one of those reports floored me.
On July 27, the Treasury Department removed 84 people and companies from its sanctions list. It corrected the information on 22 more. Back in May, the same effort had already cleared 76 names.
I read it twice, and then I sat back and admitted something I did not enjoy admitting.
I had no idea what I was looking at. (Please don’t tell me husband.)
Not the vocabulary. I know what a sanction is in the general sense, same as you do. What I did not know was what they were really talking about. How does a person get sanctioned? I honestly thought it only applied to countries. How does somebody get off that list? Do they ask, or does the government notice on its own? Is there a hearing? A judge? Does anyone ever have to explain the decision to anybody?
Here is what actually really bothered me.
That same week I had been talking with my boys how American courts are supposed to work. You are innocent until proven guilty. You get told what you are accused of. You get to answer it. There is a judge, and if you cannot afford a lawyer, the court appoints one for you. And, of course, if there really is a kids jail and what a kid would need to do to get under arrested (as my 5 year old says it).
We talked about that on Tuesday. On Thursday I found a federal system where not one piece of that applies.
So I went digging. Federal Register notices, agency guidance nobody reads, a court opinion out of Washington, and Treasury’s own record of every change it made this year, which is a spreadsheet situation I do not recommend to anybody.
Here is what I found. The system is real, it is entirely legal, it has been running for seventy five years, and five weeks before that report came out it got a brand new website almost nobody covered.
I also found something that has been bothering me ever since. The government publishes what it changed. It almost never publishes why.
OFAC stands for the Office of Foreign Assets Control, a small office inside the Treasury Department whose entire job is running America’s economic sanctions.
A sanction is financial punishment. Rather than “under arresting” somebody, the government cuts them off from money.
OFAC keeps a public list of the people it has cut off. The official name is a mouthful, so everybody just calls it the SDN List. You can search it on Treasury’s website right now with just a little digging.
Nearly everyone on that list lives outside the United States, and that is by design. The law behind it requires that the threat come from somewhere beyond our borders. It was built specifically to reach people our courts cannot.
Think about the problem it was meant to solve. If a man steals a car in Florida, police arrest him and he goes before a judge. But if someone in another country is running a scheme that hurts us. We cannot send police and “under arrest” them. The country they are in may have no interest in prosecuting. He will never set foot in an American courtroom.
So we use money instead. We cannot arrest him, but we can freeze anything of his that touches the American financial system.
The list covers a huge variety. Individuals, companies, ships, aircraft, even cryptocurrency wallets. Programs aimed at Russia, Iran, North Korea, Venezuela, Belarus, Syria, drug networks, terrorist financiers, hackers, and human rights abusers anywhere on earth.
And it is growing fast. In 2017, the government added roughly 880 names in a year. By 2024 it was adding more than 3,000.
Landing on this list is not the same as being convicted of anything.
Nobody arrests you. There is no trial, no jury, no judge. Government employees review information about you, decide you match a description written into a presidential order, and add your name.
The amount of proof required is called reason to believe.
Think about that for a minute. To send someone to prison, a jury must be convinced beyond a reasonable doubt. That is the highest standard we have. One step down is clear and convincing evidence, which judges apply in certain civil cases. Another step down is probable cause, which is what a police officer needs before a judge will sign a warrant to search your house.
And beneath all of those sits reason to believe. That is the standard used before the government freezes everything a person owns.
Everything you own inside American jurisdiction freezes immediately. Frozen does not mean confiscated. The government does not take it. On paper it remains yours. You simply cannot touch a dollar of it, possibly for the rest of your life.
Americans generally cannot do business with you either. Nobody can sell to you, buy from you, process your payments, or fix your roof. Your companies freeze alongside you. There is a provision people call the 50 percent rule: if listed people own half of a business or more, whether directly or through other companies, that business is blocked too. Even when its own name appears nowhere on any list. Imagine two listed men who each own 25 percent of a trucking company. Together that is half. The trucking company is frozen, and it may not discover this until its bank stops returning phone calls.
Nearly all of the world’s money passes through America at some point. Large international payments get settled in U.S. dollars, routed through American banks, and processed on American software. That means a company in Spain or Japan or Brazil has to screen against our list before closing a deal. Getting it wrong can cost them access to American banking, which for most international businesses is fatal.
So this is not really an American penalty. It functions more like being locked out of the world’s financial system everywhere at once.
Americans do end up on this list. It has happened to citizens, to charities, and to companies. What changes is everything that comes afterward.
The Constitution protects people here in ways it does not protect people elsewhere. When the government froze an American charity’s assets without adequate warning and without a meaningful chance to respond, a federal court stepped in and said that violated due process. The same court treated the freeze as a seizure, which brought the Fourth Amendment into it.
Someone living overseas generally cannot make that argument at all. Courts have held that the Constitution does not stretch that far. So consider carefully what is actually protecting you here.
It is not the agency being careful. It is not the statute, which does not meaningfully distinguish between you and a foreign national. It is the Constitution, and nothing else.
The men who built this country feared one thing above almost everything else. They feared power collecting in a single set of hands.
So they divided it three ways. Congress writes the laws. The President carries them out. Courts decide what is lawful and fair. Each branch keeps watch over the other two, which is what we mean by checks and balances.
Now look at how sanctions actually operate.
The President writes the criteria in an executive order. His own Treasury Department decides who fits those criteria. If you want to argue, you argue to that same department. And when courts do get involved, they mostly ask whether the agency followed its own procedures rather than whether you actually did the thing you are accused of.
One branch writes the rule, applies the rule, and reviews itself.
In fairness, the founders did give presidents genuine authority over foreign affairs, and courts have affirmed that repeatedly. This is not a power somebody invented out of nowhere.
But Congress saw the problem clearly.
In 1976 it passed a law allowing itself to shut down a President’s emergency powers by simple vote. That was meant to be the check.
It lasted seven years. In 1983 the Supreme Court ruled that kind of vote unconstitutional, and Congress rewrote the provision in 1985. Now ending a President’s emergency requires passing a bill the President can veto, and then mustering two thirds of both chambers to override him.
Read that again. To end a President’s emergency, Congress needs enough votes to defeat the very President whose emergency it is.
The check still exists on paper. It essentially never works.
There are currently 54 of these emergencies running. The oldest began on November 14, 1979, over the Iran hostage crisis. Keeping any of them alive requires a single page filed once a year. No hearing, no vote, no debate. Inertia does the entire job.
Five ways, and they all look identical in the public record.
Someone petitions. Or the agency reviews its own list and pulls entries. Or an entire program ends and everyone under it comes off at once. Or a court intervenes, which is rare. Or the listing migrates to a different legal authority, meaning the person is technically removed and still restricted.
If you are the one asking, you have to establish one of two things.
They never should have listed you. The facts at the time did not actually meet the standard. Mistaken identity. You had already resigned. The company had already dissolved.
Circumstances changed. Something after your designation removed the basis for it. You quit. The business liquidated. You genuinely separated from whatever they said you were doing.
Two things that do not qualify as arguments. Denying the allegations without evidence gets you nowhere. Neither does promising to reform going forward, because that is not proof that anything has already changed.
And if they listed you under more than one authority, you have to defeat every single one. Knocking down half the case while the rest stands accomplishes nothing at all.
On June 29, five weeks before that July announcement, OFAC launched an online system for these requests, replacing what had been an email process.
It does two things. You can file a petition asking to be removed. And you can request something called a courtesy document. That second one is the real news, and here is why it matters so much.
Tom Doshi is an Albanian businessman and a former member of that country’s parliament.
In 2018 the State Department barred him from entering the United States, saying he was involved in significant corruption. It offered no further explanation, and it did not elaborate in the annual public report it is legally required to file. It barred his wife and children as well. They are Australian citizens.
He wanted to know what the evidence against him actually was, which strikes me as a reasonable thing to want. In February 2022 he filed a Freedom of Information Act request, the law that lets ordinary people demand government records. Nothing came. He waited. In December 2023, going on two full years later, he sued.
Three and a half months after the lawsuit was filed, the government produced its first documents: 169 pages, partially blacked out, drawn from 23 records, with four additional records withheld entirely.
Then it disclosed something else. It had identified 5,487 potentially relevant records, which it proposed handing over in batches roughly every six weeks.
Run that math. You are counting in years.
And on July 22, 2024, the court dismissed every other claim he had brought. A foreign national living abroad, without substantial ties to this country, cannot claim the protections of our Constitution.
He was left with the records request. That was all he got.
It is a list of the unclassified, non-privileged information underlying your designation, and you can now request it directly through the portal. No lawsuit. No multi-year wait.
The limits are real and worth knowing before you get your hopes up. Classified material stays out. So does privileged material and law enforcement sensitive material. If your designation rests largely on intelligence reporting, you may still be swinging at something you cannot see.
But partial sight beats blindness, and it no longer requires a federal judge.
Considerably more than I expected.
Your exact name as listed and your identification number from the government’s own search tool. The date of designation. Identity documents, or registration papers if you are a company. Every alias and spelling variant. Five years of addresses and contact information. Your employment history, your sources of income, your property, and every financial account you hold, including cryptocurrency. Any legal proceedings. Every relationship you have with anyone else on the list.
Then the actual argument, with supporting evidence, addressing each legal authority and each criterion separately.
Companies produce all of that plus registration histories, owners, managers, and operators.
There is no filing fee, for whatever that is worth.
There is no deadline. None. That is the single most important operational fact in this entire article.
OFAC aims to review your submission for completeness within seven to ten business days. If it looks complete you receive a case number, which signals only that substantive review can begin. It is not a ruling on anything.
Then comes the long part, which can involve reinvestigation, consultation with other agencies, and fresh intelligence or law enforcement checks. The office says it typically tries to send a first questionnaire within about 90 days when one is needed.
Beyond that, OFAC states plainly that processing may be lengthy, depending on the facts, the completeness of your filing, your candor and promptness, whether additional questionnaires are required, and how much coordination with other agencies is involved.
No statute sets a clock. No regulation sets a clock. And status inquiries may not receive a substantive answer at all, because of volume.
Answer those questionnaires carefully. Incomplete or misleading responses can get you denied, and can create separate criminal exposure for lying to the federal government.
Nothing to file. Everything else is professional fees. (Which you know are expensive)
No authoritative fee survey exists for this work, so treat what follows as planning ranges rather than market rates.
A straightforward mistaken identity correction might run up to roughly $25,000. A focused petition with a limited factual record runs somewhere between $25,000 and $100,000. A full petition involving changed circumstances, ownership structures, or contested conduct runs from $75,000 to $300,000. Multi-jurisdictional matters requiring forensic accountants, investigators, and translators begin around $250,000 and climb from there. Litigating a denial in federal court costs considerably more.
You are permitted to file this yourself. But the cases most likely to need relief are precisely the ones least suited to a short do-it-yourself submission.
Which is a polite way of saying the door exists and the ramp does not.
In criminal court, if you cannot afford an attorney, one is appointed for you. That is a constitutional right, and every American child learns it.
Here there is nothing. No appointed counsel. No funded legal aid office. No law school clinic. Only a few dozen American attorneys handle contested removals with any regularity, and they are not cheap.
I taught my son that if you cannot afford a lawyer, one will be provided. That is true in a courtroom. It is not true here, and here is where the government can freeze everything a person owns.
Yes, and this is where my reading got genuinely interesting.
Treasury announced its modernization effort in May. Two announced rounds followed: 76 entries on May 28, and 84 on July 27 along with corrected information on 22 more.
Treasury described the removed population as including deceased individuals, decommissioned ships, defunct networks, and targets designated more than two decades ago whose records no longer contained enough detail for banks to screen against reliably.
Two things I got wrong at first, so you do not have to.
Duplicate cleanups are not releases. That July action also resolved 18 cases where the same target had been entered twice. Treasury stated explicitly that those people remain sanctioned and their property remains blocked. Anyone adding 84 and 18 to claim that 102 people received relief is simply wrong, and I very nearly was.
Removal does not always mean freedom. Sometimes a target comes off under one authority and gets designated again under a different one in the same action. The record shows a removal. Nothing actually lifts.
What surprised me most is that those two announced rounds were not the year at all.
Working through OFAC’s own change archive, there were roughly twenty seven separate removal events through July 30. All but three arrived as silent database updates with no press release and no explanation whatsoever. A row changes, and that is your notice.
You may be filing all of this under foreign criminals in countries you will never visit. Let me close that distance.
You are already paying for it. Every bank, credit union, insurer, title company, payment app, and money transmitter in this country screens its customers against that list. The cost is baked into your fees and your closing costs. That wire transfer held up for two days when you bought a car? Frequently this.
Screening software matches names, not people. Share a name or a birth year with somebody on the list and you can watch a mortgage closing slide, an account application die, or a transfer sit in limbo while a compliance department decides whether you might be a Venezuelan official. Treasury runs a dedicated hotline for this problem, which tells you how routine it is.
Banks would rather drop you than investigate you. Compliance departments do not deal in nuance. They deal in not getting fined. A customer who is merely near sanctions risk frequently just gets closed out. Relatives are not automatically designated, but joint accounts vanish and transfers bounce and the letter explaining why never arrives, because there is no letter.
Violating these rules is a serious federal crime. Doing it willfully carries up to twenty years in prison and a million dollar fine. American exporters and small business owners live under that exposure every day.
And the law already reached ordinary American businesses. On February 20 of this year, the Supreme Court ruled 6 to 3 that this same statute does not authorize a President to impose tariffs. Tariffs are taxes, the Court said, and taxes belong to Congress. But billions of dollars had already been collected from American importers before anyone stopped it.
That was the first meaningful judicial limit on this law in nearly fifty years. Notice when it arrived. Only when the power stretched toward the one authority the Constitution most plainly assigns to Congress, and only after Americans had already paid the bill.
The freezing power itself was left completely untouched.
I am aware of how that heading sounds. Stay with me anyway.
Mothers are the ones teaching this material. Not exclusively, but disproportionately, and certainly in my house. We are the ones at the table explaining what a warrant is, why the Fourth Amendment exists, and why the government has to tell you what you did before it can take anything from you.
We hand our children a story about how this country works. Notice. A hearing. The right to see the evidence. The presumption that you did nothing until somebody proves otherwise.
Then I sit down with federal filings at eleven at night and find a system containing none of it. No charge. No trial. No hearing. No appointed counsel. No deadline. No obligation to explain anything afterward.
I am not saying the story we teach is false. It mostly holds, and it holds better here than nearly anywhere on earth.
But it has an edge, and I did not know where that edge was. I have been teaching civics to my own children for years.
That bothered me considerably more than the sanctions did.
Because here is what mothers do. We notice. We notice when a bill does not add up, when a school is not telling us everything, when the answer we received does not match the question we asked. That instinct is not suspicion. It is maintenance. Institutions drift, and somebody has to keep asking.
Nobody can ask here. Not because anyone forbade it, but because the information required to ask an intelligent question is not published.
And I keep coming back to Doshi’s children. Barred from this country because of the household they happened to be born into. I have no idea whether their father did what the government says he did. Neither do you, and neither does anyone outside a locked room in Washington.
That is the entire problem.
If those were mine, I would want somebody to be able to check.
Treasury publishes what it changed. It does not publish why.
You can determine that a name came off, on what date, under which program. You generally cannot determine whether someone petitioned, whether the original designation turned out to be wrong, whether circumstances genuinely changed, whether the person died, or whether somebody in a conference room made a diplomatic trade.
Those are entirely different events, legally and morally. In the public record they look identical: a line that disappeared.
That matters practically, not just philosophically. There is no precedent to reason from. No published decisions. No comparable cases. Nobody entering this process can look at what has succeeded before and assess whether their own facts resemble it. You are guessing, and you are guessing expensively.
Other countries handle this better, which is not a sentence I enjoy typing.
The European Union must provide a written statement of reasons when it lists someone. It reviews those listings on a schedule, and the listed person can take the case to a real court.
The United Nations, of all institutions, maintains an independent officer for exactly this purpose. Someone outside the office that made the original decision gathers information from member states, engages directly with the listed person, and issues a reasoned recommendation. The full report stays confidential. Intelligence stays protected.
An independent reviewer, a reasoned decision, and a protected record, all three at the same time. Somebody already built that. We did not.
I am not asking Treasury to publish sources or methods. I would defend that secrecy against anyone. I am asking for one line stating what kind of decision it made.
I started reading because a press release confused me. I finished convinced the confusion is not an accident, and that fixing it would not cost this country a single secret.
There is a reason Scripture keeps returning to honest scales and equal weights. Not because God is particular about scales, but because a judgment nobody is permitted to inspect is not really a judgment at all. It is just an outcome somebody handed you.
I would like to be able to tell my boys we do this the right way.
Most of the time, we do.
Peace in the chaos.
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