On October 26, 2026, OFAC amended several Frequently Asked Questions (FAQs) as part of its ongoing process of reviewing published guidance to ensure information remains current. This batch includes the FAQ topics on Blocking and Rejecting Transactions and on Filing Reports with OFAC.

The update amended 11 FAQs covering three main areas:

Blocking versus rejecting transactions - clarifying when financial institutions must freeze funds because a blocked person has an interest in the property, versus rejecting a prohibited transaction when no blockable interest exists.
Reporting and recordkeeping - clarifying reporting procedures, the 10-business-day deadline for reporting blocked property and rejected transactions, supporting documentation, and annual reporting requirements for blocked property.
Operational procedures - addressing the handling of blocked accounts, interest and service charges, customer notifications, and the distinction between a customer asking about a prohibited transaction and actually instructing a bank to process one.

The updated Blocking and Rejecting Transactions

FAQs can be found here.

The updated Filing Reports with OFAC FAQs can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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