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.

Click here to watch a video discussion, in which Marwa M Hassoun and Kay C Georgi discuss the ramifications of the change and suggest possible clarifications.


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