FR 2024-30825

The document from the Department of the Treasury outlines a proposal for information collection activities related to the Office of Foreign Assets Control (OFAC). This proposal is significant as it involves the renewal and revision of information collection authority tied to various economic sanctions programs. The Treasury is also consolidating several existing requests and introducing a new form related to sanctions on Russia. Public comments on this proposal are invited and must be submitted by January 27, 2025.

General Summary

The notice published by the U.S. Department of the Treasury is rooted in ensuring that economic sanctions are effectively managed. This process involves gathering and processing information from entities such as financial institutions, businesses, and individuals who may be affected by these sanctions. The Treasury seeks to streamline the reporting process by consolidating existing information requests and adding a new form specific to the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act. The notice invites public feedback, underscoring the participatory aspect of policymaking.

Significant Issues and Concerns

One primary concern is the complexity of the language and references used in the document. It delves into specific sections of the Code of Federal Regulations (CFR) and numerous forms, which can be intricate for non-experts. This might hinder laypersons or smaller entities from fully understanding their obligations or how to fulfill them.

Additionally, the variability in the estimated frequency of responses—from as few as one to as many as 17,800 annually—suggests a complex and potentially inconsistent reporting burden. This broad range indicates significant differences in how different entities interact with the regulations, possibly owing to their size, scope, and nature of their activities. Such variability can lead to confusion about expectations for smaller versus larger organizations.

The estimated time per response similarly ranges from 1 minute to 5 hours, which might appear daunting to prospective respondents. Without clear guidelines on what types of responses fall at the longer or shorter ends of this spectrum, organizations might struggle to allocate resources appropriately.

Public Impact

On a broad level, the document represents the federal government's commitment to maintaining oversight over entities subject to economic sanctions. It seeks to balance compliance and enforcement with clarity and efficiency in reporting requirements. For the general public, this oversight might contribute to national security objectives and international compliance.

However, the administrative burden implied by such extensive reporting requirements could be seen as a negative impact. Smaller entities, in particular, might find themselves overwhelmed by the reporting obligations, potentially requiring them to devote substantial resources to compliance efforts that could otherwise support their operational activities.

Impact on Specific Stakeholders

For financial institutions and larger business entities, the organized and detailed response requirements might be an expected part of their compliance frameworks. While the renewal and revision of reporting forms might demand adjustments, these entities are likely to have the necessary infrastructure and expertise to cope.

In contrast, nonprofits, smaller businesses, and individual respondents could face significant challenges. The complexity of forms and the varied response times may impose additional burdens, particularly where resources are constrained. The introduction of new forms, like the REPO for Ukrainians Act Report Form, further emphasizes the need for entities to stay informed and nimble to comply with evolving requirements.

Overall, while the updated requirements aim to enhance the effectiveness of sanctions and reporting, they also present practical challenges that stakeholders must navigate to maintain compliance.