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On December 30, 2025, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) removed the SDN List records for Sara Hamou, Andrea Gambazzi, and Merom Harpaz. Each deletion entry carries the program code CYBER2. OFAC’s public notice identifies the removals but does not explain why they were made.
What OFAC’s December 2025 update says
OFAC’s December 30, 2025 SDN List update lists deletions for Sara Hamou, Andrea Gambazzi, and Merom Harpaz. The entries are marked CYBER2, a program code associated with the sanctions record. The update is the official public record for the deletions; it is not an explanatory announcement.
The action was removal of these records from the Specially Designated Nationals and Blocked Persons (SDN) List. The update does not say whether the individuals sought removal, what evidence OFAC considered, or whether any conditions apply.
How the removals relate to the 2024 designations
The deletions came after two Treasury actions targeting people and entities associated with the Intellexa Consortium. Those earlier announcements establish the sanctions context, but they do not state the reason for the later removals.
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- March 5, 2024: Treasury announced that OFAC designated two individuals and five entities associated with Intellexa. The department described the consortium as involved in developing, operating, and distributing commercial spyware. It said that property of listed persons within U.S. jurisdiction was blocked and that certain transactions were prohibited. Read Treasury’s March 2024 announcement.
- September 16, 2024: Treasury announced a separate action designating five individuals and one entity associated with Intellexa. Read Treasury’s September 2024 announcement.
These designation releases explain the earlier actions. They should not be read as an explanation for why Hamou, Gambazzi, and Harpaz were removed in 2025.
Why were the three people removed?
The public OFAC deletion notice does not give a case-specific reason. It also does not provide a petition history or a finding that circumstances changed. The notice’s silence does not establish that no explanation exists elsewhere; it means the cited public deletion record does not disclose one.
Treasury’s July 2026 announcement describes a broader sanctions reconsideration portal launched on June 29, 2026. It says petitioners may seek removal by showing that the basis for designation was insufficient or that circumstances have changed under 31 C.F.R. § 501.807. That later, general process does not establish that any of the three used the portal or explain the December 2025 deletions. Read Treasury’s July 2026 announcement.
Congressional oversight followed in February 2026
In February 2026, senators wrote to Treasury and State asking for briefings on the delistings, including the administration’s justifications and their implications. The letter reflects lawmakers’ oversight concerns and request for information; it does not establish the government’s reasons or whether a briefing took place. Its descriptions of the individuals’ prior roles are the senators’ characterizations, not new OFAC findings. Read the Senate letter.
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How to check the current sanctions-list status
Sanctions-list records can change after an update. For the latest list data and search, use OFAC’s Sanctions List Service. The December 30, 2025 notice records the deletions on that date; it should not be treated as a guarantee of anyone’s status on a later date.
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