In the case of the European Union, you write to the European Council and you make observations explaining why you think you should not be on the list. As I said in my opening remarks, the response, in my experience, is very frustrating, because it will be very slow and it will usually not really engage with the substance of the observations. That is a failing, in my view, and it's why there are so many court cases. You only have a two-month time limit to get to the European Court to challenge the lawfulness of your listing.
Usually what happens is that people write to the European Council. They don't hear back, and they have to then make an application for judicial review in the European Court. That's the point at which they will see the evidence that is said to support their designation. They have to go through a lengthy court process, including appeals and possible re-listings. So I think the answer to your question is that it's very unsatisfactory.
In the case of the U.S., the administrative process with OFAC for delistings is more effective in the sense that there is a real administrative process that doesn't involve going to court, but I think anyone dealing with OFAC delistings would say that it's extremely difficult to be delisted from an OFAC list unless you can in some sense say that things have changed since the original designation. You might be able to be delisted administratively. The courts in the U.S. are much more deferential to OFAC than the European courts have been in the sense that the standard for overturning an OFAC decision is extremely high.
In the case of the United Nations, finally, the only process for delisting is one that's known as the “focal point”, which in my view is not an effective way of dealing with delisting requests, and requires the support of one's own country, which very often is not forthcoming. The only sanctions list in the United Nations that has a proper degree of due process, in my view, is the al Qaeda and ISIL sanctions list, which has an ombudsperson process that does provide real due process. They review all the evidence underlying listings and make a recommendation to the Security Council as to whether there should be a delisting. But the ombudsperson process is only for one of all of the UN's many sanctions lists.