OFAC puts kingpins on the “kingpin list” also known as the “Clinton List” But many people who get on the list are not kingpins—far from it.
Once official word gets around that you are on the list, banks in the U.S. will close your accounts. In fact, banks in other countries may close your accounts as well and cancel your credit cards although they are not required to do so.
Your lawyer can determine the basis for putting you on the list by reviewing the “administrative record” which he or she will request from OFAC. You may challenge your designation on the list. But I can tell you from experience that getting on the list is much easier than getting off it.
In time, however, the government has the burden to demonstrate to a court why an individual should still be on the list, and your argument should be that you should no longer be on the list. If OFAC refuses to remove you, (a likely probability,) you can and should challenge the decision in court. That is when they almost always settle with you. If they settle with you, that means you will be removed from the list. OFAC is not an organization that makes decisions about who gets off the list, they are more like cops, they just do what they are told. You’ll get your justice in court.
– David Zapp and Johanna Zapp