In June 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control, or OFAC, significantly changed the scope of reporting requirements related to so-called rejected transactions, particularly in terms of expanding the reporting base beyond financial institutions and funds transfers.

In February, OFAC issued FAQs to confirm that these reporting requirements apply to companies outside the financial sector.However, OFAC has not provided public guidance to nonfinancial sectors seeking to comply with U.S. sanctions about which types of transactions should be reported under Title 31, Section 501.604 of the Code of Federal Regulations.

After providing background on OFAC reporting requirements, this article proposes a common-sense framework for companies seeking to comply with OFAC’s rejected-transactions reporting requirements.

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