OFAC reporting that drafts every blocked and rejected report with its sources, counts the 10 business days for you, and files only when the OFAC Officer signs
Every OFAC report filed in 10 business days, every blocked dollar tied to the ledger.
See one case, screen by screen ↓OFAC Reporting is a solution in which agents prepare OFAC reporting for a bank's sanctions team: they draft each blocked property, rejected transaction and unblocking report field by field with its sources, count the 10 business days, tie blocked accounts to the general ledger for the annual report and keep a sealed 10-year record set. The BSA/OFAC Analyst prepares and the OFAC Officer approves and files.
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OFAC reporting starts when a bank blocks or rejects a payment. Within 10 business days a report must reach OFAC through the OFAC Reporting System. Blocked funds must sit in an interest-bearing blocked account on the general ledger. Every blocked dollar goes on the annual report of blocked property, as of June 30 and due September 30. And since March 21, 2025, every record is kept 10 years, double the old five. At a community bank this is one BSA/OFAC analyst, an officer, a spreadsheet and a calendar: the analyst finds the payment message, the core record and the disposition, types each field into OFAC's form, sends it to the officer by email and saves the receipt to a shared drive.
The failures are quiet until the exam. The clock is counted in calendar days or across a federal holiday. A hand-off arrives days late from a fintech partner's processor and silently eats the 10 days. “SDN” is written as the legal authority, which the rules do not allow. A block never reaches the ledger, or sits in suspense. A blocked account is opened in a product that earns no interest. And a record is purged at year five under a retention schedule that is now wrong.
Estimated split of the hours an analyst and an officer spend on one blocked or rejected item at a community bank today, by hand and with the solution.
Seven agents count the clock, draft every field with its source and prove each link; the analyst prepares, the OFAC Officer files.
Tessaly Community Bank rejected a $2,450.00 international ACH credit on Friday, October 2, 2026. Here is item OFR-2026-0033 link by link, as the people and agents in the working solution carried it, ending on day 6 of 10.
The payments hub holds an incoming international ACH (IAT) credit of $2,450.00 for business customer Harbor Lane Provisions LLC. The IAT addenda name the originator, Pars Golden Trade Co., Tehran, Iran, and payment screening raises a hit. Owen records the disposition at 2:51 PM: no listed person, a payment for Iranian-origin goods. At 2:58 PM the OFAC Officer, Lena Marchetti, decides: reject.
Deposit Operations returns the entry to the gateway with Nacha return code R16, and journal entry JE-2026-1002-0211 clears the suspense account. Rosalind approves the return. A minute later the Intake agent takes the decision, attaches the payment message, the disposition and the customer record, and opens the item's custody chain.
The Clock agent counts 10 business days from Friday, October 2: Monday to Friday, without federal holidays. Saturday and Sunday do not count, Columbus Day on Monday, October 12 does not count, and the report is due Monday, October 19. Asked how it got there, it lists every day with its reason.
Mon, Oct 12 · Federal holiday: Columbus Day · not counted.
On day 1 the drafting agent fills all 7 fields 31 CFR 501.604(b) asks for: who is reporting and a contact, the transaction and its parties, any sanctions target, the date rejected, the value in U.S. dollars, the legal authority and the payment instructions. Each value carries a confidence and a source chip. The legal authority names the program, the Iranian Transactions and Sanctions Regulations, never “SDN”.
Owen reads the draft and changes one field, the description of the transaction. He adds the gateway operator and “Payment for invoice INV 2026-118, 4 kg of Iranian-origin saffron”, gives reason code OV-1, and sends the report to the officer. The draft and his change stay side by side.
OV-1: the draft left out the invoice and the gateway operator.
On the same morning, the fintech partner's processor hands off OFR-2026-0036, an outgoing $31,500.00 transfer rejected on Tuesday, October 6. The Intake agent starts the clock at the rejection, not the hand-off: 4 of 10 days are used on arrival, due Wednesday, October 21. It flags the missing payment instruction for Owen to request.
Lena opens the report as the checker. She sees the one field Owen changed beside the agent's draft, 7 of 7 fields complete and the legal authority named. She ticks “I have read the report and its sources. File it with OFAC under my name.” and signs. The analyst could not have signed it, and she could not sign anything she prepared.
Only after her signature, the agent submits the report through the OFAC Reporting System and records receipt ORS RJ-2026-118402. The chain closes on day 6 of 10. Rejected transactions are not blocked property, so this one never goes on the annual report. The record set is sealed with a checksum and kept until October 2, 2036.
Five blocked accounts hold $84,661.24, but ledger 2185-00 holds $80,541.24. The $4,120.00 difference is BA-0005, opened October 8 for a check payable to a listed entity, with no journal entry. The agent proposes the entry; Rosalind Kerr posts it and the OFAC Officer confirms it.
The agent never posts an entry or changes a rate.
In online banking and at the branch, Harbor Lane Provisions LLC sees the $2,450.00 credit as returned to the sending bank. Branch staff get a neutral script that connects the customer to the BSA/OFAC Officer. The screening hit, the OFAC report and any case or referral stay with sanctions staff.
The same blocked and rejected items, seen by the four people who carry them: what their day looked like, and what it looks like now.
Seven agents count the clock, draft every field with its source and prove each link; the analyst prepares, the OFAC Officer files.
Takes each block or reject decision from sanctions alert review, payment screening or the fintech partner's processor, attaches the payment message, the disposition and the customer record, and opens the custody chain.
Counts 10 business days from the event date without weekends and federal holidays, sets reminders on days 3, 5 and 7, and escalates on days 8 and 9.
Drafts the blocked property, rejected transaction or unblocking report, each field cited to its source, and drafts notices to customers.
Proves each link of the custody chain against its system of record, from the hit to the receipt, and draws a missing link open with the person who must close it.
Ties every blocked account to general ledger 2185-00 at each month-end and when an account opens, and checks each account's rate against the comparable rate.
Builds the annual report of blocked property as of June 30 from the month-end tie-outs, in OFAC's layout, ready on July 1.
After the officer signs, submits through the OFAC Reporting System, records the receipt, seals the record set with a checksum, sets its retention date and builds examiner packs.
Approves and files every report. The agents propose; a named person decides.
Ask in plain words. The answers cite the payment, the decision, the ledger or the rule they come from, and open the screen that goes with them.
Why is OFR-2026-0033 due on October 19?
The IAT credit was rejected on Friday, October 2, and a rejected transaction report is due within 10 business days. Counting Monday to Friday without federal holidays, October 5 to 9 are days 1 to 5, Columbus Day on October 12 does not count, and October 13 to 16 and 19 are days 6 to 10. Due Monday, October 19; today is day 6.
What must a rejected transaction report contain?
Seven things, to the extent known when it was rejected: who is reporting and a contact; the transaction, its parties and references; any sanctions target; the date rejected; the value in U.S. dollars; the legal authority, never “SDN”; and copies of the payment instructions. The draft of OFR-2026-0033 has all 7, each cited.
Do the blocked accounts tie to the general ledger?
Not today. The five blocked accounts hold $84,661.24 and ledger 2185-00 holds $80,541.24. The $4,120.00 difference is BA-0005, opened October 8, with no journal entry. Rosalind Kerr posts it and the OFAC Officer confirms. Every account earns 3.85%, the comparable rate.
Prepare the FDIC examiner pack for 2026
The pack holds January 1 to October 13: every item with its custody chain, the reports as filed with their receipts, approvals and return codes, the 5 blocked accounts with their tie-outs and interest, and the annual report filed September 24. Account numbers are masked to the last 4. Choose the audience and build it.
13 screens from the working solution, on its sample data. Pick one to see it large.
The Compliance Systems Administrator edits the settings and every save is a new version. Rule changes, such as a new closure, an escalation or the rate rule, wait for the BSA/OFAC Officer.
| Setting | Default | Choose from |
|---|---|---|
| A business day is | Monday to Friday, not a federal holiday | Your holiday calendar; bank-only closures do not stop the clock |
| The clock starts | The date property is blocked, the transaction rejected, or property unblocked or transferred | Never the hand-off date; reports are due 10 business days later |
| Reminders and escalations | Day 3 analyst, day 5 with the officer, day 7 officer reminder, day 8 Deputy BSA Officer, day 9 Chief Risk Officer | Your days and people; escalation changes wait for the officer |
| “SDN” as a legal authority | Refused: the program regulation is named instead | A library of program authorities, one per sanctions program |
| Blocked funds | Blocked savings, at the money market rate for comparable balances (3.85% today), on ledger 2185-00 | Your product, rate rule and ledger account; tie-out at each month-end and when an account opens |
| Drafted fields marked for the analyst | Below 0.90 confidence | A threshold per agent, with versioned prompts and models and override codes OV-1 to OV-3 |
| Record retention | Sanctions records 10 years; blocked property while blocked and 10 years after; BSA records 5 years | The longer applies; legal holds for an examination or litigation need a second approval |
| Customer data by role | Outside the sanctions team, account and tax IDs to the last 4 | Redaction profiles for the FDIC and state examiners, internal audit and the BSA Officer |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “estimated” = our estimate of where an analyst's and an officer's hours go on one OFAC report · “typical” = published figures: OFAC civil penalties in 2025 and 2024 (a published law-firm review) and the inflation-adjusted penalties for a late annual report of blocked property (a 2026 law-firm note). Rules: 31 CFR 501.603 and 501.604 (reports within 10 business days; annual report as of June 30, due September 30), 31 CFR 501.601 (10-year records, effective March 21, 2025), 31 CFR 594.203 (blocked interest-bearing accounts), 31 CFR 1010.430 (BSA records). Tessaly Community Bank, its customers, the businesses, the listed entities, the receipts and the people named on this page are fictional: characters and sample data in the working solution.
OFAC Reporting is a solution in which agents prepare OFAC reporting for a bank's sanctions team: they draft each blocked property, rejected transaction and unblocking report field by field with its sources, count the 10 business days, tie blocked accounts to the general ledger for the annual report and keep a sealed 10-year record set. The BSA/OFAC Analyst prepares and the OFAC Officer approves and files.
Under 31 CFR 501.603 and 501.604, a report on blocked property or a rejected transaction is due within 10 business days, filed through the OFAC Reporting System. Blocked property is also listed on the annual report of blocked property, as of June 30 and due September 30, and records are kept 10 years under 31 CFR 501.601. The solution drafts each report against the fields the rule asks for and cites every value.
The Clock agent counts Monday to Friday, without federal holidays, from the date the property was blocked or the transaction rejected, never from the hand-off date. Asked how a date was counted, it lists every day with its reason. A late hand-off shows the days already used on arrival.
No. The Filing and records agent submits through the OFAC Reporting System only after the OFAC Officer has signed, then records the receipt and seals the record set. The analyst cannot approve a report, and what the officer prepared goes to the Deputy BSA Officer.
The Blocked funds agent ties every blocked account to the general ledger at each month-end and checks that each earns the comparable rate. On July 1 the Annual report agent drafts the report as of June 30 from those tie-outs, so the analyst reviews it and the officer files it well before September 30. In the working solution the 2026 report was filed on September 24 with a $0.00 difference.
No. Customer-facing views and branch scripts use neutral wording, such as “returned to the sending bank”. A screening hit, an OFAC report, a case number, a referral or a SAR stays with the sanctions team.
Yes. Agents count, draft, tie out and propose; they never decide, post an entry, change a rate, sign, file unsigned or delete a record. The analyst prepares, the OFAC Officer approves and files, the deputy signs what the officer prepared, and Deposit Operations posts ledger entries for the officer to confirm.
The Agentic Solution Engine builds and deploys it from your requirements and documents (your holiday calendar, escalation path, legal authority library, blocked-funds product and ledger accounts, and a sample of past reports), and it goes live once every quality gate has passed. We will walk you through it on your own blocked and rejected items first.
A pile of articles becomes one cited story, decided in minutes.
1-min demoPEP ScreeningEvery PEP hit settled with its sources, and PEP treatment ends the day the rules allow.
1-min demoSanctions Ownership & ControlEvery blocked share traced to its source; the 50% call made while the payment is held.
1-min demoWe'll run OFAC Reporting on a sample of your own past blocked and rejected items and your blocked accounts.