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TCH Submitted a Comment Letter on OFAC’s Interim Final Reporting Rule

TCH submitted a comment letter to the Office of Foreign Assets Control (OFAC) regarding its interim final rule revising certain reporting, procedures, and penalties regulations. TCH requested that OFAC clarify the types of “goods and services” transactions that must be included in rejected transaction reports and requested that OFAC provide guidance on whether the reporting obligation for rejected transactions depends on the reporting institution’s role in a transaction.  TCH also commented that OFAC’s preference that blocked property and rejected transaction reports be submitted via email is problematic for some financial institutions and encouraged OFAC to develop other electronic reporting methods.

Download the full comment letter here.