Question of the Week: OFAC E-Filing and Record Retention

Posted: Dec 13, 2024 | Author: Cornerstone Compliance Team

Electronic Filing OFAC Record Retention

Question:

Have there been changes to the Office of Foreign Assets Control (OFAC) regulations pertaining to electronic filing and record retention?

Answer:

Yes. An Interim Final Rule was issued in May that was effective Aug. 8, 2024, that requires filers to use the electronic OFAC Reporting System (ORS) for submission of initial and annual reports of blocked property and reports of rejected transactions.

A Final Rule was issued in October, effective Nov. 7, 2024, clarifying that unblocked or transferred blocked property reports are not required for certain types of transactions. See the Final Rule, page 81361, Subpart C, Section 501.603(b)(3)(i) for a list.

Per another Interim Final Rule issued in September, effective March 12, 2025, OFAC is increasing its record retention period from five to 10 years. Although the Interim Final Rule could be amended to extend the effective date, credit unions should prepare to retain OFAC records for 10 years.

For additional information, please see the rule links embedded in this article, and these

America’s Credit Unions blog posts:

1) OFAC Compliance – The Never-Ending Story

2) OFAC to Require Use of Electronic Reporting System Blog