Further details from Ballard Spahr:
"In addition, reports of rejected transactions must include, among other information:
- a description of the transaction;
- the identities of parties “participating in transaction” including “customers, beneficiaries, originators, letter of credit applicants, and their banks”;
- names of intermediary, correspondent, issuing, and advising or confirming banks;
- a description of the property “that is the subject of the transaction”;
- account or reference numbers;
- the identities of “associated sanctions targets” (e.g., sanctioned parties who are not direct or disclosed parties to a transaction);
- the actual known or estimated value of the transaction;
- a “narrative description” of the “value of a shipment” related to “rejected trade documents” (e.g., letters of credit); and,
- copies of transaction documentation, such as bills of lading, invoices, or “other relevant documentation received in connection with the transaction.”
Parties newly required to report rejected transactions to OFAC should take steps to align their documentation and record keeping practices with amended § 501.604."
OFAC’s revision to the rejected transactions regulation requires reporting parties to state with greater specificity the legal basis for rejecting transactions. Prior to the June 21 amendment, financial institutions were required to “state the basis for” rejecting funds transfers. As of June 21, reporting parties are required to state in reports the “legal authority or authorities under which the transaction was rejected,” such as references to specific OFAC-administered sanctions programs or provisions of OFAC sanctions regulations. As discussed below, the specificity required by the amended rule should be considered in assessing the compliance burden imposed by the IFR.