The effectiveness of economic sanctions depends not only on the substantive prohibitions and penalties they impose but also on the procedural framework through which they are administered and enforced. Using the United States (US) as a case study, this article argues that the procedures governing sanctions designations administered by the Office of Foreign Assets Control (OFAC) constitute an independent mechanism for reinforcing sanctions pressure because OFAC designations are governed by a procedural framework in which the safeguards ordinarily afforded in civil and criminal proceedings – such as prior notice, disclosure of evidence, meaningful opportunities to be heard, effective avenues of appeal, and broader due process protections – are substantially curtailed in the name of national security and foreign policy. This procedural framework is further reinforced by the highly deferential standard of judicial review under the Administrative Procedure Act, under which US courts generally defer to OFAC’s factual findings and discretionary judgments rather than reassessing the merits of OFAC designations. As such, US persons and those subject to US jurisdiction are strongly incentivized to comply with US sanctions because an OFAC designation carries immediate and severe legal and economic consequences, with only limited opportunities to challenge or overturn the designation.