Partner Giovanna Cinelli spoke with Global Investigations Review about the ongoing delays within the US Office of Foreign Assets Control (OFAC), and how lawyers often have little insight to their cause. Giovanna explained that lawyers or parties can appeal to the agency, noting that a non-answer is effectively a denial of their request, or file a Freedom of Information Act (FOIA) requesting the details of OFAC’s decision-making process. “We have used FOIA to escalate the request, noting that the lack of responsiveness has resulted in an inability to determine how to proceed,” she said.