Fox Chat: Discussing the OFAC Sanctions Reporting Rules
International Trade Partners Kay Georgi and Marwa Hassoun have an update on OFAC’s changes to the Reporting, Procedures and Penalties Regulations, 31 CFR §§ 501, et seq. related to reporting blocked, unblocked, or rejected transactions.
In an interim final rule on June 21, 2019, OFAC expanded the scope of the RPPR to include any US person (or person subject to US jurisdiction) instead of just financial institutions, as previously required.
Under the revised RPPR, US persons have 10 days to report to OFAC when they “reject” “transactions” that would be illegal to engage in. Last week, OFAC issued two new FAQs (819 and 820) clarifying that, yes, OFAC was, in fact, serious when it expanded the reporting requirements. In this Fox Chat, Kay and Marwa opine on the ramifications of the change and suggest possible clarifications.
Contacts
- Related Practices