31 CFR § 501.604 Reports on rejected transactions (With Version Proposed in 5-8-24 Interim Final Rule)

Date issued: May. 08 2024

Last substantive commentary amendment:
Oct. 09 2024

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TURBOFAC Commentary (1653 words)

Update – on 5-8-24, OFAC published an “Interim final rule” announcing amendments to this RPPR provision and others, to be effective 90 days after its 5-10-24 publication in the FR. The left side of the screen includes the revised provision and the pre-existing provision. See the back of the PDF file for the Interim final rule and a redline comparing the revised and pre-existing versions.

The amended version of this provision found in the Interim final rule makes a number of consequential changes vis-à-vis the pre-existing version.

(i) “Any Means Any”

In language unchanged from the revised and pre-existing versions of this provision, the reporting requirement is described as applying to “[a]ny U.S. person (or person subject to U.S. jurisdiction), including a financial institution…” In the FR Notice Introducing Changes to RPPR, OFAC removes whatever doubt...