Limited functionality available
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:
As a Manager on the Global Export Controls & Sanctions team in London, Julia has worked on compliance-enhancing projects for clients in a variety of industries, including oil and gas, aerospace & defence, manufacturing and the technology, media and telecommunications industries. She is experienced in US, EU, UK, French, German and other EU Member State military, dual-use and sanctions regulations. Julia’s experience includes conducting trade compliance risk reviews and audits and assisting clients with the development of internal compliance programmes. She specialises in identifying areas of risk and opportunity in relation to management of trade sanctions, particularly in relation to US and EU sanctions on Russia and Iran. Julia has been involved in conducting ITAR audits in UK, France, Poland, and Brazil for non US Aerospace & Defense companies. Julia holds a degree in French and German and a Master of Arts from the University of Cambridge.