820. I am required to submit a rejected transaction report to OFAC, but I do not have all the information that is required to be reported pursuant to 31 CFR § 501.604(b). Am I required to collect such information from my counterparty just to complete my rejected transaction report?
OFAC expects U.S. persons and persons otherwise subject to U.S. jurisdiction to provide all information required by Section 501.604(b) of the RPPR that is in the filer’s possession in a rejected transaction report, and generally does not expect reporters to seek further information from their counterparty solely to obtain additional information required to be reported under Section 501.604(b). However, OFAC would expect at a minimum that all rejected transaction reports include required information that is applicable in all reject scenarios (e.g., information regarding the submitter of the report, the date the transaction was rejected, the legal authority or authorities under which the transaction was rejected, and any relevant documentation received in connection with the transaction). [02-20-2020]
1) Refer to 31 CFR § 501.604 Reports on rejected transactions. The wording of the FAQ seems to suggest that while a U.S. person need not solicit a (potentially sanctioned) counterparty for information for the purposes of filling out a rejected transaction report, a U.S. person may do this without such correspondence constituting a receipt of "services" from a sanctioned person.