OFAC Reporting Rules Change


Treasury’s Office of Foreign Assets Control is issuing an interim final rule to amend the Reporting, Procedures and Penalties Regulations (RPPR), to require electronic filing of certain submissions to OFAC and to describe and modify certain reporting requirements related to blocked property and rejected transactions.

In particular, the rule would

  • require use of the electronic OFAC Reporting System for submission of reports related to blocked property and rejected transactions,
  • remove the mail option for certain other types of OFAC submissions,
  • describe reports OFAC may require from financial institutions for transactions that meet specified criteria, and
  • add a reporting requirement for any blocked property that is unblocked or transferred.

Additionally, OFAC is clarifying the scope of the reporting requirement for rejected transactions, in part to respond to comments received on the interim final rule OFAC published on June 21, 2019 to amend the Regulations.

Further, OFAC is modifying the procedures for requests relating to property that is blocked in error and updating the Regulations with respect to the availability of information under the Freedom of Information Act (FOIA) for certain categories of records.

Petition for removal from SDN Lists

OFAC is also clarifying that persons may submit a petition for administrative reconsideration to seek removal of a person or property from the List of Specially Designated Nationals and Blocked Persons or any other list of sanctioned persons maintained by OFAC.

Reporting Requirements

OFAC is also adding a description of reports OFAC may require financial institutions to provide about transactions that meet specified criteria to aid in the identification of blocked property.

Finally, OFAC is making several technical and conforming edits. OFAC is soliciting public comments for 30 days on this interim final rule.


The Regulations (31 CFR part 501), originally issued August 25, 1997 (62 FR 45098), set forth standard reporting and recordkeeping requirements, license application procedures, and other procedures relevant to the economic sanctions programs administered by OFAC.


In a client note published May 20,  Akin Gump's OFAC team points out:

"The revisions appear to make it such that “sales or purchases of goods or services” must be reported to OFAC, as opposed to all transactions “related to…goods or services.”

"Under the previous proposed formulation of § 501.604, the term “transaction” appeared to cover all transactions “related to…goods or services,” which could be read as covering a great deal of activities.

"In contrast, under the new proposed formulation, the context of “goods and services” is limited to “sales or purchases” of goods and services."

OFAC is providing updates within nine sections of the Regulations: §§ 501.602, 501.603, 501.604, 501.605, 501.801, 501.804, 501.805, 501.806, and 501.807.

Reporting, Procedures and Penalties Regulations


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