The Office of Foreign Assets Control has issued a final rule that, effective Nov. 7, will amend its Reporting, Procedures, and Penalties Regulations to add three exceptions to the reporting requirement for any blocked property that is unblocked or transferred.
The RPPR set forth standard reporting and recordkeeping requirements, license application procedures, and other procedures relevant to the economic sanctions programs administered by OFAC.
In May 2024 OFAC issued an interim final rule making a number of amendments to the RPPR, including requiring the use of the electronic OFAC Reporting System for submitting reports related to blocked property and rejected transactions, describing reports OFAC may require from financial institutions for transactions that meet specified criteria, requiring reports within 10 business days of when blocked property is unblocked or transferred, clarifying the scope of the reporting requirement for rejected transactions, and modifying the procedures for requests relating to property that is blocked in error.
In response to comments on that rule, OFAC is amending the RPPR to clarify that reports need not be submitted for (1) blocked property that is unblocked or transferred pursuant to a general or specific license (unless that license includes a condition that requires the submission of an unblocking report), (2) blocked property that is unblocked pursuant to the removal of a person from the specially designated nationals list, and (3) authorized transfers of funds or credit by a financial institution between blocked accounts in its branches or offices or authorized debits for normal service charges. OFAC declined to make any changes in response to comments on other issues.
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