Filing Reports with OFAC

31 C.F.R. Parts §§501.603 and 501.604 require blocking and reject reports to be submitted to OFAC within 10 business days of the date of the action. Optional reporting forms are available at this link and complete information may be emailed to OFAC’s Sanctions Compliance and Evaluation Division at ofacreport@treasury.gov. Blocking and reject reports must contain a copy of the original transfer instructions.

Yes. A report of blocked property is to be submitted annually by September 30 to OFAC Compliance, Department of the Treasury, Washington, D.C., 20220. The standardized form can be accessed by visiting this link. If you wish to use a different format, please contact the OFAC Compliance hotline with any questions. For Guidance on Filing the Annual Report of Blocked Property, visit this link.

Yes, effective June 21, 2019, OFAC amended the Reporting, Procedures and Penalties Regulations, 31 CFR part 501 (RPPR), to provide updated instructions and incorporate new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions. In addition, this rule includes information regarding OFAC’s electronic license application procedures and provides additional instructions regarding applications for the release of blocked funds.

OFAC expects all U.S. persons and persons otherwise subject to U.S. jurisdiction, including parties that are not U.S. financial institutions, to comply fully with all requirements of this rule, including the expanded requirement in Section 501.604 of the RPPR to provide reports to OFAC regarding rejected transactions within 10 business days of the rejected transaction. (Previously, only U.S. financial institutions were required to submit reports to OFAC for rejected funds transfers.) Reports on rejected transactions are to be submitted to OFAC, preferably electronically, as specified by OFAC’s Reporting and License Application Forms webpage.​

OFAC accepted comments from the public on this rule, which it continues to review. In addition, OFAC welcomes further feedback as we assess whether any clarification or modification to the rule is appropriate, including: additional information regarding the business impact of this rule; examples of rejected transactions that are proving challenging to report; the quantity of rejected transactions; and the types of information in the filer’s possession for a rejected transaction report. Feedback and questions regarding the rule should be submitted to OFAC Compliance hotline.

OFAC expects U.S. persons and persons otherwise subject to U.S. jurisdiction to provide all information required by Section 501.604(b) of the RPPR​ that is in the filer’s possession in a rejected transaction report, and generally does not expect reporters to seek further information from their counterparty solely to obtain additional information required to be reported under Section 501.604(b). However, OFAC would expect at a minimum that all rejected transaction reports include required information that is applicable in all reject scenarios (e.g., information regarding the submitter of the report, the date the transaction was rejected, the legal authority or authorities under which the transaction was rejected, and any relevant documentation received in connection with the transaction).

If you have blocked and reported property due to mistaken identity or typographical or similar errors, you may unblock such property and file an unblocking report with OFAC consistent with the procedures described in 31 CFR 501.603(b)(3).  With respect to the information described in 31 CFR 501.603(b)(3)(ii)(F), the reporting person can cite FAQ 1196 in their unblocking report to indicate that the property was released due to mistaken identity or typographical errors, rather than an OFAC authorization like a general or specific license.  Please note, unblocking property in which a blocked person does in fact have an interest without authorization from OFAC could expose U.S. persons to civil penalties.

Alternatively, you may seek to have such property unblocked pursuant to the administrative procedures detailed at 31 CFR 501.806, known as a "Compliance Release."

OFAC strongly encourages organizations subject to U.S. jurisdiction to develop risk-based sanctions compliance programs that allow for the proper evaluation and adjudication of potential name matches to blocked persons. Organizations should not use the Compliance Release process as a substitute for internal controls to mitigate the risk of transactions or dealings in blocked property. 

Organizations should not request a Compliance Release in situations in which property was correctly blocked, but the status of the property has subsequently changed (e.g., a change in the portion of ownership by a blocked person).  In such scenarios, organizations should apply for a specific license. The Compliance Release process is solely for cases of mistaken identity or typographical or similar error, in which there was never a blockable interest in the subject property (e.g., a name match to a blocked person that the reporting organization later determines, with reliable supporting evidence, to be a false positive). Please note neither a specific license nor a Compliance Release is required to unblock property when a person is delisted from the Specially Designated Nationals and Blocked Persons List.

The Compliance Release process is only available to the organization who blocked the property; thus, if a financial institution or other organization has blocked your property and you are requesting that the property be unblocked, you should engage directly with the financial institution or other organization that blocked your property in cases of mistaken identity or apply for a specific license.

Organizations must retain records as related to the transactions described above. See 31 CFR 501.601 and 31 CFR 501.602 of the Reporting, Procedures and Penalties Regulations for applicable recordkeeping and reporting requirements.