On December 4, 2000, the Judicial Review Commission on Foreign Asset Control issued a report to Congress pursuant to the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”) recommending greater openness and responsiveness by the Office of Foreign Asset Control and greater formal administrative review of final OFAC actions. The Commission found that the provision of the Act restricting judicial review of designations by the Secretary of the Treasury, while not unconstitutional, is both unnecessary and inconsistent with the accountability of government actions inherent in sanctions programs established pursuant to the International Emergency Economic Powers Act (IEEPA) and in numerous other regulatory schemes…[more]