Regarding OFAC: I know there is a requirement to submit the Annual Report of Blocked Property to OFAC; however, on there website, there are also two forms that indicate they are voluntary for reporting blocked/rejected transactions. Does anyone know why these are voluntary? I thought we had to report.

Also, if we don't have any blocked/rejected transactions, are we required to file a "NIL" report with OFAC or maintain on file with the bank a copy of a report indicating we had no blocked/rejected transactions for the year?

I'd appreciate your help!

This is off of the Treasury/OFAC website FAQ's. Also, not mentioned here-if you don't have anything to report a report is not required.

When a transaction is rejected or blocked, I have ten days to report it. Do I have to do it in writing or can I call OFAC Compliance and report it that way?

At the moment, OFAC requires that all blocking and reject reports be submitted in writing. Optional reporting forms are available at this link. Reports may be mailed in or faxed to OFAC Compliance at 202-622-2426. Blocking and reject reports must contain a copy of the original transfer instructions. OFAC is currently working with the financial community on a pilot project to permit the filing of such reports electronically. If you wish to participate in the pilot project, please contact OFAC Compliance. [09-10-02]

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Is there a requirement for annual reporting of blocked property? Is there a required format?

Yes. A report of blocked property is to be submitted annually by September 30 to OFAC Compliance, Department of the Treasury, Washington, D.C., 20220. The standardized form can be accessed by visiting this link. If you wish to use a different format, please contact OFAC's Blocked Assets Division at 202-622-2440. [09-10-02]

Perhaps the voluntary reports listed on their website is part of the pilot program. Thanks Sonic!!

I think it's the use of *their* forms that is voluntary. You have submit the information to them (in writing) if you have a blocked/rejected transaction.