On May 10, 2024, The Office of Foreign Assets Control (OFAC) has released a new proposed rule which would make significant changes to OFAC’s standard reporting, record-keeping, and license applications under U.S. sanction programs.

Key Takeaways

Below, we provide an overview of the key changes contained in the proposed rule:

• Electronic Only, Please! Eliminates the option to submit reports by mail; only electronic submissions will be accepted.
• Prompt Reporting Required. Mandates the reporting of any blocked property that is either unblocked or transferred, within 10 business days following the action.
• All Transactions Welcome Here! Covers the reporting of rejected “transactions,” defined to include all dealings involving securities, checks, foreign exchange, and the sale or purchase of goods or services.
• No Info? No Problem (Sometimes). Clarifies that if information normally required by OFAC is not readily available at the time a transaction is rejected, it is not mandatory for that information to be reported.
• Direct Contact. Designates a contact point for questions about OFAC’s general licenses, at ofacreport@treasury.gov.

Next Steps

Stakeholders can submit written comments on the proposed rule via the Federal eRulemaking Portal or, ironically, by mail to OFAC until June 10, 2024. The proposed rule (incorporating any changes OFAC may make based on comments on this interim final rule) will become effective August 8, 2024.