On 21 June 2019 the Office of Foreign Assets Control (OFAC) issued an interim final rule expanding the scope of the Reporting, Procedures and Penalties Regulations (RPPRs)(1) with regard to reporting blocked, unblocked or rejected transactions to include any US person (or person subject to US jurisdiction) instead of just financial institutions, as previously required.

Under the revised RPPRs, US persons have 10 days to report to OFAC when they reject transactions in which it would be illegal to engage. At the end of February 2020, OFAC issued two new FAQs (819 and 820) clarifying that it was serious when it expanded the reporting requirements.

In the below video, Marwa M Hassoun and Kay C Georgi discuss the ramifications of the change and suggest possible clarifications.

For further information on this topic please contact Marwa M Hassoun at Arent Fox LLP's Los Angeles office by telephone (+1 213 629 7400) or email ([email protected]). Alternatively, contact Kay C Georgi at Arent Fox LLP's Washington DC office by telephone (+1 202 857 6000) or email ([email protected]). The Arent Fox LLP website can be accessed at www.arentfox.com.

Endnotes

(1) Procedures and Penalties Regulations, 31 CFR §§ 501, et seq.