On Oct. 7, OFAC issued amendments to recordkeeping requirements.
OFAC made amendments to Reporting, Procedures and Penalties Regulations (RPPR).
Follows interim rule that was published in May 2024, effective Aug. 2024 #211554.
Final rule adds three exceptions to requirement for unblocked property reporting.
Amendments
RPPR (31 CFR 501) sets forth standard reporting and recordkeeping requirements and license application and other procedures relevant to the economic sanctions programs.
Clarifies that reports need not be submitted for authorized transfers of funds or credit by a financial institution between blocked accounts in its branches or offices.
Also for blocked property that is unblocked or transferred pursuant to a general or specific license, unless license includes requirement to file an unblocking report.
Third, blocked property unblocked by OFAC's removal of a person from the SDN List.
OFAC is implementing these changes to reduce the reporting burden on the public for unblocking actions, something OFAC generally does not have a strong interest in.
Requires every person engaging in transactions subject to provisions to keep full and accurate record of such, regardless if transaction is conducted pursuant to a license.
