NEW YORK – Troutman Pepper Locke secured a significant victory on behalf of a Chinese artist when the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed the artist from the Specially Designated Nationals and Blocked Persons List on Oct. 21, 2026, without requesting supplemental information. Following a delisting petition, the artist’s U.S. assets were unfrozen, and the artist returned to doing business in U.S. markets and with U.S. persons.
The designation was based on allegations that the artist engaged third-party vendors in a sanctioned country. OFAC froze the artist’s U.S. assets and cut off access to the U.S. financial system and commercial markets, putting the artist’s career and livelihood at risk. In response, the firm prepared and submitted a delisting petition that directly addressed the basis for the designation.
Troutman Pepper Locke conducted a thorough factual investigation into the artist’s vendor relationships, payment flows, and production chain. The petition was supported by well-organized declarations, financial records, and translated materials that anticipated OFAC’s questions.
The filing required the team to draw on its deep experience working across language, cultural, and legal system differences to explain the U.S. sanctions process, as the artist’s supporting evidence was in Chinese, and the artist does not speak English. The team explained the artist’s rights and obligations in terms they could fully understand while presenting the facts to OFAC accurately and in context. This cross-cultural understanding and approach contributed to the result.
Delisting petitions usually involve multiple rounds of follow-up questions and document requests, making removal without supplemental requests an exceptional outcome. The result reflects the completeness and credibility of the submission and the team’s judgment and discipline throughout the process.
The Troutman Pepper Locke team that secured this victory was led by Ryan Last, Ziwen Zhu, and Beichen Chen, who played crucial roles in the investigation and successful filing of the delisting petition.
Troutman Pepper Locke’s national team offers comprehensive representation in U.S. sanctions, export controls, imports, foreign direct investment, and related areas, guiding clients through the complex and ever-changing landscape of global trade compliance. The firm provides services in compliance counseling, cross-border transactions, due diligence, internal controls development, license applications, and enforcement representation. Troutman Pepper Locke’s attorneys also assist clients in engaging with key government decision-makers to influence U.S. policies and regulations.
Troutman Pepper Locke
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