The United States (U.S.) Office of Foreign Assets Control (OFAC) has imposed a new reporting requirement on U.S. persons for transactions or property “blocked” (property being frozen) or “rejected” (declining of financial transactions or transactions in goods or services), “where processing or engaging in the transaction would nonetheless violate” OFAC sanctions.
This is a significant change in reporting obligations for businesses, as the regulation means that any U.S. person or person subject to U.S. jurisdiction must within 10 days report to OFAC whether a transaction was rejected due to involvement of OFAC sanctioned territories or OFAC’s list of Specially Designated Nationals (SDNs).
The OFAC Reporting, Procedures and Penalties Regulations (31 CFR Part 501) lays out the several new reporting requirements as follows:
The expansion of information listed in § 501.603 that is required for submission in reports on blocked property, unblocked property, and rejected transactions, means that:
Julia leads Deloitte’s Global Export Controls & Sanctions team in London. She has led compliance-enhancing projects for a number of years in a variety of industries, including financial services, consumer products, oil and gas, aerospace & defence, manufacturing and the technology, media and telecommunications industries. She is a specialist in US, EU, UK, French, German and other EU Member State military, dual-use and sanctions regulations. Julia has a thorough understanding of the export control challenges faced by companies involved in international trade activities. More broadly, Julia supports her clients in developing integrated compliance programmes to manage their regulatory compliance requirements (including export controls, ABAC and data privacy), with a focus on lean business requirements to manage regulatory obligations. Julia has also been involved in the development of a number of different technology solutions to manage export compliance requirements, and has supported clients to develop and implement their digital strategies for effective compliance management.