Behind every designation is an administrative record and a legal standard — which makes it, structurally, an APA case. Courts grant these challenges rarely but really, and the litigation posture changes OFAC's administrative behavior even before any ruling.
Some designation records include classified material courts review ex parte. That asymmetry is real and survivable: cases have turned on the adequacy of unclassified summaries and on what the open record fails to support. Expect it, brief around it, and make the government own every inference in daylight.
A reconsideration petition strengthens the record and courts prefer seeing it, but rigid exhaustion is argued case-by-case — sequencing is strategy, not formula.
Vacatur and remand — the designation set aside for a lawful redo — or, as often, a delisting that arrives administratively once litigation discipline enters the room. Both count.
The District of Columbia hears the bulk of designation challenges — OFAC's home venue and this firm's home court.