OFAC Amendments

OFAC recently published an Interim Final Rule to amend its Reporting, Procedures and Penalties Regulation (31 CFR part 501).  This section deals with the reporting, recordkeeping, and licensing requirements for OFAC’s economic sanctions programs.

In the past, if a submitter did not provide sufficient information to identify blocked or unblocked property or to determine the authority under which the property was blocked or unblocked, OFAC had to request follow up information which might result in multiple requests. This Rule expands and clarifies the information that is required to be submitted to OFAC in reports on blocked property to reduce the need for follow up requests.  This should lessen the overall reporting burden for submitters.

The Interim Final Rule:The Interim Final Rule:

  • provides updated instructions and incorporates new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions;
  • revises the licensing procedures section to include information regarding OFAC’s electronic license application procedures and to provide additional instructions regarding applications for the release of blocked funds; and,
  • clarifies the rules governing the availability of information under federal law…for information that is submitted to OFAC in connection with blocking or unblocking reports, reports on rejected transactions, or license applications.

This Interim Final Rule was effective June 21, 2019; however, written comments may be submitted until July 22, 2019.

Published
2019/07/10

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David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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