OFAC Introduces Reporting Rule That Applies to All U.S. Companies

The Office of Foreign Assets Control (OFAC) introduced an interim rule that expands mandatory reporting requirements for all U.S. persons. The rule requires all U.S. persons to file reports with OFAC when a transaction is rejected because the transaction would have resulted in an OFAC violation. The interim rule will remain in effect until OFAC considers the comments received and issues a final rule.

The reporting requirement expands OFAC’s jurisdiction in two key ways.

First, proactive reporting requirements are extended to U.S. persons selling goods and services. Second, the reporting requirement applies to all rejected transactions based on sanctions compliance, not just incidents of rejected fund transfers.