Demonstrating OFAC ComplianceAn effective OFAC compliance framework must be able to demonstrate compliance with the Reporting, Procedure and Penalties Regulations (RPPR), consistently and at scale. Electronic filing is no longer optional; companies are required to use the OFAC Reporting System (ORS) to file initial reports on blocked property, reports on rejected transactions and the Annual Report of Blocked Property (ARBP). Consistent with the statute of limitations for certain OFAC sanctions violations, the agency updated its record retention requirements in 2025 from five to 10 years. Blocked property reports must be filed within 10 business days and then annually until the property is unblocked. The company failed to report blocked property for more than 45 months, resulting in a $7.1 million penalty.