OFAC Updates Contact Info and Swaps Legal-Fee Reporting for Recordkeeping
OFAC is finalizing administrative updates to several CFR parts, including refreshed website and contact information and a notable change to general licenses covering payments for legal services from funds originating outside the United States — replacing a reporting requirement with a recordkeeping requirement. Firms that rely on these general licenses (e.g., when a sanctioned-country counterparty pays legal fees) now need to maintain records rather than file reports. Compliance teams should update their sanctions compliance procedures to reflect the recordkeeping obligation.
What to do
- Update your sanctions compliance policy and general license procedures to replace any legal-services reporting workflows with the new recordkeeping requirement, and confirm your OFAC contact and web references are current.
Who this affects
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Source
Read the official publicationThis radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.