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ARTICLE · 23 MAY 2024

OFAC Revamps Reporting Requirements

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On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations at 31 C.F.R. Part 501 to, among other things, ...

United StatesInternational Law
Mahmoud Baki Fadlallah
Mahmoud Baki Fadlallah
Ryan P. Fayhee
Ryan P. Fayhee
Nnedinma Ifudu Nweke
Nnedinma Ifudu Nweke
Jason Prince
Jason Prince
Wynn Segall
Wynn Segall
Lauren Talerman
Lauren Talerman
Andrew R. Schlossberg
Andrew R. Schlossberg
Orfeh Vahabzadeh
Orfeh Vahabzadeh
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Key Points

  • On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to blocked property and rejected transactions. Subject to any changes OFAC may make following a 30-day comment period, the proposed changes will become effective on August 8, 2024.
  • Notably, the IFR would:
    • Narrow the definition of "transactions" for purposes of the rejected transactions reporting requirement under § 501.604(a) such that rejected "sales or purchases of goods or services" must be reported to OFAC, as opposed to all transactions "related to...goods or services."

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