How to Choose Law Firms Working on OFAC: A Beginner’s Setup Guide
The short answer: start by confirming that a firm actually handles OFAC matters as a core practice, not as an occasional favour for an existing client. Then check who signs the engagement letter, whether the firm is admitted in the right jurisdiction, and how it structures the work when a designation touches more than one country. If you get those three things right on the first screening call, you avoid most of the expensive mistakes beginners make.
I teach this process to people who have never hired a sanctions lawyer before. Most of them arrive with the same confusion: they search for law firms working on OFAC, find dozens of websites that all sound identical, and have no idea how to tell them apart. So let me walk you through it the way I walk my students through it — as a series of questions you should be asking, in order.
What does “working on OFAC” actually mean in practice?
OFAC is the Office of Foreign Assets Control, the US Treasury body that administers and enforces economic sanctions. A firm “working on OFAC” is doing one or more of a small number of recognisable tasks.
The first is delisting and removal: representing a person or entity that has been placed on the Specially Designated Nationals list, or on a sectoral or non-SDN list, and petitioning for removal. The second is licensing: applying for specific or general licences so a transaction that would otherwise be prohibited can proceed. The third is compliance counselling: building screening programmes, training staff, and reviewing transactions before they happen. The fourth is enforcement defence: responding to subpoenas, administrative subpoenas, or penalty notices.
Ask any firm which of those four it does most often. A firm that mostly does compliance counselling for banks will not necessarily be the right choice if your problem is a designation. A firm that runs delisting petitions every month is a different animal entirely. Beginners often assume “sanctions lawyer” is one job. It is at least four.
How do I screen a firm before the first paid hour?
This is the question I get most often, and the answer is a checklist rather than a single test.
Check the practice page, not the homepage. A firm that genuinely works on OFAC will have a dedicated sanctions practice page listing matters, attorneys, and often published guidance or client alerts. If the only mention of sanctions is a paragraph buried in a general “international trade” page, treat that as a yellow flag.
Check the register. Confirm the individual lawyer is admitted and in good standing where they claim to practise. Directories that verify credentials against official registers save you this step, because the verification has already been done and you can compare jurisdictions side by side rather than chasing bar association websites one by one.
Check who is on the engagement letter. Ask directly: is the person I am speaking to the person who will sign, or an intake coordinator? Some firms use business development staff for first calls, and that is fine, but you should know before you share sensitive facts.
Check the conflict position. Sanctions work frequently involves multiple parties, some of whom may be adverse. A firm that already acts for a bank in a related matter may be conflicted out. Ask early.
Check the fee structure. Delisting petitions and licence applications are usually handled on a fixed fee or a staged fee, because the scope is defined. Compliance programme work is usually hourly or retainer. If a firm quotes hourly for a delisting petition without a scope document, ask why.
Why do jurisdiction differences matter so much?
Here is where beginners get caught out. OFAC is a US regime. The EU and the UK run their own sanctions frameworks, and while they overlap heavily with US measures, they are not identical. A person listed by OFAC is not automatically listed by the EU or the UK, and vice versa. The reverse is also true: you can be clear in Washington and still be caught by EU and UK sanctions listings.
That means your choice of firm depends on where you actually sit. If you are a US person, or you use US dollars, or you touch US-origin goods, OFAC jurisdiction reaches you. If you are an EU resident with EU assets, the EU regime matters most, and a purely Washington-focused firm may not be the efficient choice. If you hold a UK passport or bank in London, the UK’s Office of Financial Sanctions Implementation is the relevant authority.
Ask the firm a simple question: “Which regimes do you file under, and how many filings have you made under each in the last twelve months?” A firm that only files in the US will tell you so. A firm that files in all three is rare and usually larger. Most people need two out of three, and knowing which two saves both time and money.
How should I compare firms across different platforms?
This is the part of the lesson where I slow down, because it is where the setup differs from platform to platform.
If you are using a general search engine, you will get a mix of firm websites, news articles, and directory listings. The problem is that search rankings reward marketing spend, not expertise. A firm with a strong SEO team can outrank a genuinely better practitioner.
If you are using a bar association or regulator’s register, you get accuracy but no comparison. You can confirm a lawyer exists and is licensed, but you cannot easily see whether they have ever filed a delisting petition.
If you are using a specialist directory, you get the middle ground: verified credentials plus the ability to filter by jurisdiction and by the type of sanctions work. That is the setup I recommend for beginners, because it removes the two biggest sources of error — unverified claims and apples-to-oranges comparison. The point is not that any one platform is perfect. The point is that you should know which platform you are on and what it is optimised to show you.
What should the first call actually cover?
Treat the first call as a scoping exercise, not a sales pitch. You want four things out of it.
First, a plain-language summary of your position: are you listed, at risk of being listed, or trying to avoid a transaction problem? Second, a realistic timeline. Delisting petitions can take months, sometimes longer, and any firm promising a fast result should be asked to explain how. Third, a scope document with defined deliverables. Fourth, a named point of contact with a direct line.
If you are also exploring residency or citizenship options alongside a sanctions matter, say so on the first call. Some firms handle both, some handle only one, and the coordination between them matters. A good firm will tell you honestly where its competence ends.
One more thing: do not share documents on the first call. Establish the engagement terms first. Any reputable firm will expect that.
Questions beginners ask me most
Can one firm handle OFAC, EU, and UK matters at the same time?
Some can, usually the larger international practices with offices in Washington, Brussels, and London. Smaller firms typically focus on one regime and refer the rest. There is nothing wrong with a referral, as long as the referring firm stays involved and you are not left coordinating three separate teams yourself.
How much does it cost to work with a sanctions firm?
It varies enormously by matter type. Compliance reviews and screening programme work are usually the least expensive because the scope is bounded. Licence applications sit in the middle. Delisting petitions and enforcement defence are the most expensive, because they involve detailed factual investigation, submissions, and often a long wait. Ask for a staged fee proposal so you can pause between stages if needed.
Is a directory listing the same as a recommendation?
No. A verified listing tells you that the lawyer’s credentials check out against official registers. It does not tell you that the firm is the best fit for your specific matter. Use the directory to build a shortlist, then screen the shortlist yourself using the questions above.
What is the single biggest mistake beginners make?
Hiring on the strength of a website. Sanctions work is document-heavy and jurisdiction-specific. The firm’s marketing tells you almost nothing about whether it has filed under the regime that applies to you. Ask for numbers, not adjectives.