An article from Michael Volkov on 6th August is concerned with a seemingly small change made to OFAC rules on blocked or rejected transactions in June which, it says, greatly expands the reporting requirements and places a potentially large burden on US persons and entities. Previously, only financial institutions were required to report rejected “funds transfers”, but now any US person who rejects a transaction for any transaction, including goods and services must report this to OFAC. There is, it says, no guidance on what constitutes a rejected transaction, especially when it comes to internal corporate deliberations. Reports are required within 10 days of rejection.
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