OFAC updates FAQs on blocking and rejecting transactions

27 October 2026

OFAC has amended 11 FAQs on blocking and rejecting transactions and filing reports. The FAQs apply across all OFAC sanctions regimes. OFAC says the update is part of its ongoing review of published guidance. See our US Guidance page for all OFAC guidance.

Under the amended FAQs, all reports on blocked property, rejected transactions and annual holdings go through the OFAC Reporting System. Reports on blocked property and rejected transactions are still due within 10 business days. They must now include supporting documents, such as invoices or bills of lading, not just the original transfer instructions. Anyone holding blocked property on 30 June each year must file an annual report on a set form by 30 September of that year.

Blocked funds must now sit in a segregated, interest-bearing account. Where firms use an omnibus account, the annual report must list each blocked asset separately.

The guidance on opening accounts now covers all US persons, not only financial institutions. Firms may tell customers which sanctions regime they blocked their property under. A new example covers rejecting a wire transfer to a non-blocked person in Crimea. FAQ 53 confirms that a bank does not need to file a reject report when a customer only asks whether a payment is allowed.

FAQ 10 now lists the jurisdictions under broad US sanctions: Cuba, Iran, North Korea, Crimea, and the so-called Donetsk and Luhansk People’s Republics. It also lists the governments whose property is blocked: Cuba, Iran, North Korea and Venezuela.