International Trade & Regulatory Advisory

Community News

OFAC Now Requires All U.S. Companies to Report Business Rejected Due to Sanctions

The U.S. Office of Foreign Assets Control (OFAC) has greatly expanded the requirements for who must report transactions that are rejected due to sanctions. In an unexpected move, on June 21, 2019, OFAC modified its regulations to require all U.S. persons—not just financial institutions—to report any transaction that is “rejected” due to sanctions. This change could have a broad impact on U.S. businesses that, until now, have not been obligated to report such rejected transactions.

As a U.S. Company, What Should I Do Next?

U.S. companies of all sizes may have reporting obligations under the amended regulation. To help meet these obligations, our International Trade & Regulatory Group can assist companies in conducting a sanctions risk assessment, developing reporting policies and procedures, and providing real-time guidance on whether a business opportunity declined for sanctions concerns is a “rejected” transaction that must be reported.

For reading the full advisory document follow the link bellow: