The Clearing House Association (TCH) submitted comments to the Office of Foreign Assets Control (OFAC) regarding its interim final rule amending certain reporting, procedures, and penalty provisions of OFAC regulations. TCH requested that the new requirement for reporting the unblocking of blocked property within 10 business days be narrowed to apply only when an unblocking is done pursuant to a non-OFAC action. TCH suggested that reports of unblocked property that are done pursuant to OFAC action should be provided annually or semi-annually. Additionally, TCH requested that OFAC establish a reasonable time frame within which it must make a final determination when it directs a bank to hold and report transactions based on non-public information. Last, TCH asked OFAC to clarify that new sections of the regulation regarding actions taken or transfers of blocked property only apply to actions taken or transfers that are external to the person holding the blocked property.
 
A copy of the letter may be found here.