OFAC FAQ (Current) # 1196 - Filing Reports with OFAC

Date issued: Oct. 07 2024

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TURBOFAC Commentary (727 words)

Notes:

1) 31 CFR § 501.806 sets out OFAC's "Procedures for unblocking property believed to have been blocked and reported in error due to mistaken identity or typographical or similar errors," in which OFAC articulates a process for seeking the unblocking of such property. Here OFAC, for the first time, issues what is effectively an authorization for the unblocking of such property without OFAC intervention, though OFAC still requires the submission of an unblocking report pursuant to 501.603(b)(3) (of which 501.603(b)(3)(ii)(F) requires an explanation of the "[t]he legal authority or authorities under which the property was unblocked or transferred. This may include, for example, reference to a specific or general license under an applicable part of this chapter or an E.O.," which in cases such as these is a null set, hence OFAC's instruction to simply cite to the...