OFAC Modernization Recap; Publication of Amended FAQs

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Treasury’s Office of Foreign Assets Control (OFAC) announced several new outreach initiatives to complement their recent website upgrades and video series.

GENERAL FREQUENTLY ASKED QUESTIONS (FAQS) UPDATE 

 The first installment of updated FAQs is available now (FAQs 1, 3, 4, 6, 7, 9, 10, 11, 12, 13, 91, 126, 468, and 469) and includes guidance on key topics such as what OFAC means by “blocked property” and how to verify the authenticity of an OFAC document. 

OFAC will announce subsequent FAQ updates via its Recent Actions Notices

OFAC WEBSITE UPDATES AND FAQS SEARCH FUNCTION 

The website now has a new and improved FAQ search function that allows you to search by keyword or phrase and to filter results by specific topics or relevant sanctions programs. 

FAQ ARCHIVE   

In addition to updating certain FAQs and enhancing the search function, OFAC is working to make it easier for the public to see when FAQs have been updated and what has changed. 

Specifically, we will soon begin preserving certain older versions of amended FAQs in an FAQ archive on our website.  

COMPLIANCE HOTLINE

Last year, OFAC’s Compliance Hotline received approximately 57,000 submissions — an all-time high. 

To keep up with the increased demand for sanctions guidance, OFAC launched a new online platform to streamline the way the public submits queries to OFAC.  

OFAC REPORTING SYSTEM

In 2019, OFAC introduced the OFAC Reporting System (ORS)., a secure electronic platform for submitting reports related to blocked property and rejected transactions.  

It offers features such as secure messaging, bulk filing, and unique report forms.  ORS has been available as an optional filing method since 2019.  

Recently, OFAC amended the Reporting, Procedures, and Penalties Regulations to clarify reporting requirements and make the use of ORS mandatory for filing block and reject reports.  This rule took effect on August 8, 2024.

SANCTIONS LIST SERVICE 

On May 6, 2024, OFAC formally launched the Sanctions List Service (SLS).,  a cloud-based platform that provides users with easy access to the most up-to-date and complete sanctions lists and sanctions list data ready for immediate download. 

SLS introduced a custom sanctions dataset tool to allow users to create custom datasets based upon their selection of certain sanctions lists or programs.  SLS also provides easy access to an archive of OFAC’s sanctions lists in XML format (dating back to 2022).  Human-readable versions of sanctions lists (dating back to 1994) remain available on OFAC’s website.

PRODUCTION SUBMISSION STANDARDS AND ENFORCEMENT INFORMATION

On July 5, 2024, OFAC published an update to its data delivery standards, which provides general and technical guidance for submitting information to OFAC electronically.

The guidance, available here, provides best practices for organizing submissions, general conventions for electronic submissions of various file types, and standards for submitting large productions. 

Additionally, on April 8, 2024, OFAC’s table of Civil Penalties and Enforcement Information was updated to include the dates, party names, penalty or settlement amounts, and relevant documentation for enforcement actions dating back to 2003. 

LICENSING PORTAL

OFAC recently updated the online Licensing Portal to provide greater transparency about the license application process.  

Specifically, applicants using the Licensing Portal to check the status of their applications will now receive one of ten case statuses that specify where their application is in the processing timeline.  Concurrently, OFAC updated the License Hotline by revising menus and transitioning to a callback-only system.  These updates are designed to help the public access the information they need faster, reduce call wait times, and improve the overall customer experience.

 

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