31 CFR § 501.603 - Reports on blocked property (With Version Proposed in 5-8-24 Interim Final Rule)

Date issued: Oct. 07 2024

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TURBOFAC Commentary (2180 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) Clarity Concerning Applicability in ITSR and Ordinary Sanctions Program Contexts

When the RPPR were first issued in 1997, this provision specified that it applied to “U.S. persons (or persons subject to U.S. jurisdiction
in the case of parts...