In late June, with minimum notice or fanfare, the U.S.
Department of the Treasury’s Office of Foreign Assets Control
(“OFAC”) issued an interim final rule (the
“Interim Rule”) that, inter alia, introduced
new, broad requirements for covered parties to report rejected
transactions. The Interim Rule amended the Reporting, Procedures
and Penalties Regulations (“RPPR”), 31 C.F.R. §
501 et seq., which set out reporting, recordkeeping, and
license-related procedures relevant to the economic sanctions
programs administered by OFAC. These changes took effect on June
21, and OFAC has invited comments on the Interim Rule through July
22, 2019.
Background
Persons subject to U.S. jurisdiction—including, for
purposes of the Cuba and Iran sanctions, non-U.S. entities that are
majority-owned or controlled by a U.S. firm—are subject to
certain blocking and reporting requirements under U.S. economic
sanctions. In particular, covered parties have long been required
to block the
