Sanctions Delisting: Procedures and Remedies in the United States, United Kingdom and European Union

This ARGA Observatory report compares procedures for challenging and removing sanctions designations in the United States, United Kingdom and European Union. It examines administrative reconsideration, judicial review, evidentiary requirements and the respective roles of the competent authorities. Case studies include Deripaska, Shvidler and Dalston Projects, Kadi II, Mazepin, and Aven and Fridman. Six hypothetical scenarios address the preparation of a delisting request, changed circumstances, renewed applications and the implementation of favourable decisions. This publication includes the Russian and English versions.