Last week, the Office of Foreign Assets Control (OFAC) announced an interim final rule which amends the recordkeeping and reporting requirements relating to the various economic sanctions programs it enforces. Notably, the amendments confirm that the requirement to report and preserve records relating to blocked or rejected transactions applies not only to US financial institutions, but also to other non-financial institutions, both foreign and domestic, that are engaged in certain covered transactions subject to US jurisdiction. In addition to expanding the scope of the recordkeeping requirements, the amendments mandate electronic filing of reports through OFAC’s online portal. The interim final rule will become effective in August 2024 following a brief comment period.
