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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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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