AWACSMortgage compliance intelligence from Flightline

Federal Register · Final rule FR Doc. 2024-23217 · Published

OFAC Reporting, Procedures and Penalties Regulations: exceptions to unblocked property reporting

OFAC adopts its May 2024 interim final rule as final and adds exceptions to the 10-business-day report required when blocked property is unblocked or transferred. This is a sanctions reporting rule outside residential mortgage lending, and it imposes no new obligation.

InformationalEffective Nov 7, 2024All checks passedRead the rule ↗ (opens in a new tab)

Loan impact

From the rule text · verified

Applies to: Persons subject to OFAC sanctions reporting requirements; the rule does not address residential mortgage loans.

Exceptions
Authorized debits to blocked accounts for normal service charges; Authorized transfers between blocked accounts within a financial institution; Unblocking or transfer authorized by a general or specific license, unless the license requires a separate unblocking report; Unblocking following OFAC removal of a person from the SDN List
Effective
Nov 7, 2024
Applicability confidence
Verified: every row above is supported by the source text
Supporting quotes from the rule
  • exceptions“OFAC is amending § 501.603(b)(3)(i) to clarify that reports need not be submitted pursuant to that section for: (1) authorized transfers of funds or credit by a financial institution between blocked accounts in its branches or offices or authorized debits for normal service charges; (2) blocked property that is unblocked or transferred pursuant to a general or specific license, unless the license includes a condition that requires the submission of an unblocking report; or (3) blocked property that is unblocked pursuant to OFAC’s removal of a person from the SDN List.”
  • guide sections“OFAC is amending § 501.603(b)(3)(i) to clarify that reports need not be submitted pursuant to that section for: (1) authorized transfers of funds or credit by a financial institution between blocked accounts in its branches or offices or authorized debits for normal service charges; (2) blocked property that is unblocked or transferred pursuant to a general or specific license, unless the license includes a condition that requires the submission of an unblocking report; or (3) blocked property that is unblocked pursuant to OFAC’s removal of a person from the SDN List.”

What changed

From the rule text · Section § 501.603(b)(3)(i)
RequirementPreviouslyNow
Exceptions to report on unblocked or transferred blocked propertyRelaxedPreviously: Reports were required within 10 business days of when blocked property is unblocked or transferred, including under a valid order of a U.S. agency or court.Reports need not be submitted for authorized internal transfers or service-charge debits, licensed unblockings or transfers (unless the license requires a report), or unblocking after SDN List removal.

What to do

AWACS interpretation · not source language

What to review: No change is mandatory: this OFAC rule relaxes the unblocked-property report, effective 2024-11-07, and does not address residential mortgage loans. A lender subject to OFAC reporting may rely on the exceptions for authorized internal transfers and service-charge debits, licensed unblockings or transfers (unless the license requires a report), and unblocking after SDN List removal.

QC implications

  • No new mandatory requirement is stated, so QC has no new required test from this rule.
  • If the lender is subject to OFAC reporting, QC may check that any decision not to submit an unblocked-property report rests on one of the stated exceptions: authorized internal transfers between blocked accounts or service-charge debits, licensed unblocking or transfer where the license does not require a report, or unblocking after SDN List removal.
  • QC may confirm that a report is still handled where a license includes a condition requiring an unblocking report.

Source and record

Version 1 · archived

Checks passed

  • Schema valid
  • Effective quotes verbatim
  • Document ID appears in the source
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  • Mandatory status is backed by requirement language
  • Mandatory entries have requirement language
  • Published on present
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  • No placeholder tokens
  • Source link resolves
  • Loan impact quotes verbatim
  • Loan impact vocabulary
  • Changes quoted
  • Impact type consistent
  • Every required change is backed by obligation language
  • Only new or tightened changes are marked required
  • Loan impact covers every required change
  • Quotes are complete sentences
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  • Diff complete
  • Mandatory date resolved
  • Audience verbatim
  • Scope residential
  • Out of scope
  • Published in window
  • Interpretation schema valid
  • Interpretation separate