OFAC Compliance: The Neverending Story

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America’s Credit Unions has released a new blog post about the Office of Foreign Assets Control (OFAC) compliance reporting requirements. In short, the post covers OFAC’s interim final rule requiring filers to use the electronic OFAC Reporting System (ORS) to submit initial and annual reports of blocked property and reports of rejected transactions beginning on Aug. 8, 2024. The rule also requires electronic submissions of reports of unblocked or transferred blocked property via email or the ORS when authorized by a valid order from a U.S. government agency or U.S. court.

OFAC finalized this rule in October, effective Nov. 8, clarifying that the unblocked or transferred blocked property reports are not required for certain other conditions. 

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. 

Make sure you understand the rule’s requirements. Read more.