Background

The Department of the Treasury’s Office of Foreign Assets Control has issued an interim final rule amending the reporting, procedures, and penalties regulations to provide updated instructions and incorporate new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions. The interim rule is effective June 21 and any written comments may be submitted by July 22.

OFAC is also revising the licensing procedures section of the regulations to include information regarding its electronic license application procedures and to provide additional instructions regarding applications for the release of blocked funds. In addition, OFAC is clarifying the rules governing the availability of information under the Freedom of Information Act for information that is submitted to OFAC pursuant to the regulations. Finally, the agency is making numerous technical and conforming edits throughout the regulations.

Sandler, Travis & Rosenberg’s export controls and economic sanctions professionals can help exporters develop and implement effective SCPs. For more information, please contact export compliance attorney Kristine Pirnia at (202) 730-4964.

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