appeal. STANDARDS OF REVIEW We review de novo the district court’s decision on cross-motions for summary judgment. Trunk v. City of San Diego, 629 F.3d 1099, 1105 (9th Cir.2011). “We review de novo questions of law, including constitutional rulings, resolved on summary judgment.” Nader v. Cronin, 620 F.3d 1214, 1216 (9th Cir.2010) (per curiam), cert. denied, — U.S.—, 131 S.Ct. 1844, 179 L.Ed.2d 772 (2011). We review for clear error the district court’s factual findings. Sapp v. Kimbrell, 623 F.3d 813, 821 (9th Cir.2010). The judicial review provisions of the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(2)(A), govern challenges to OFAC’s designation decisions. See Alaska Dep’t of Envtl. Conservation v. EPA 540 U.S. 461, 496-97 & n. 18, 124 S.Ct. 983, 157 L.Ed.2d 967 (2004) (<HOLDING>); see also Vigil v. Leavitt, 381 F.3d 826, 833
holding that when considering an agency action as to which the statute does not specify the standard of review the courts of appeals must proceed pursuant to the apas general standard of review for agency actions in 5 usc  7062a holding an agency decision is not final during the time the agency considers a petition for review holding that the standard of proof for dischargeability actions is the preponderance of the evidence standard holding that the standard of review for the sufficiency of the evidence is the same as the standard for denying a motion for a directed verdict holding that the appropriate standard of review is abuse of discretion