OFAC Amendments

OFAC recently published an Interim Final Rule to amend its Reporting, Procedures and Penalties Regulation (31 CFR part 501).  This section deals with the reporting, recordkeeping, and licensing requirements for OFAC’s economic sanctions programs.

In the past, if a submitter did not provide sufficient information to identify blocked or unblocked property or to determine the authority under which the property was blocked or unblocked, OFAC had to request follow up information which might result in multiple requests. This Rule expands and clarifies the information that is required to be submitted to OFAC in reports on blocked property to reduce the need for follow up requests.  This should lessen the overall reporting burden for submitters.

The Interim Final Rule:The Interim Final Rule:

  • provides updated instructions and incorporates new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions;
  • revises the licensing procedures section to include information regarding OFAC’s electronic license application procedures and to provide additional instructions regarding applications for the release of blocked funds; and,
  • clarifies the rules governing the availability of information under federal law…for information that is submitted to OFAC in connection with blocking or unblocking reports, reports on rejected transactions, or license applications.

This Interim Final Rule was effective June 21, 2019; however, written comments may be submitted until July 22, 2019.


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