and from Page 32…
Transports may not attack without being accompanied by at least 1 unit with an attack value, unless they are conducting an amphibious assault from a friendly sea zone that is free of enemy submarines.
Subs do not block loading… But they do block unloading unless the territory that your offloading is friendly. If your offloading onto an enemy territory then its considered an attack and the sub will block the unloading of the transport unless its accompanied by a warship (DD, CA, BB, CV).