Once it is determined that funds need to be blocked, the funds must be placed into a segregated, interest-bearing account on a U.S. financial institution's books, from which only OFAC-authorized debits may be made. The holder of the blocked funds must then report the funds as blocked property to OFAC through the OFAC Reporting System (ORS) within 10 business days, pursuant to 31 CFR § 501.603. To register for access, or to log in to ORS, please see the OFAC Reporting System page on OFAC's website.
When blocking funds, some institutions open separate accounts for each blocked transaction, while others opt for blocked omnibus accounts. Either method is consistent with regulatory requirements, provided there is a clear audit trail, including so the institution can later unblock specific funds with the appropriate interest, if authorized to do so. Please note, pursuant to 31 CFR § 501.603(d)(1), institutions maintaining blocked funds in omnibus accounts must include in their Annual Report of Blocked Property a disaggregated list showing each blocked asset contained within the omnibus account. For more information on annual reporting of blocked property, see FAQ 50.
Please see OFAC's answers to FAQs on Filing Reports with OFAC for more information. For information on blocking digital currency, see FAQ 646. For information on blocking within the insurance industry, see FAQ 62. If, after reviewing this guidance, you have questions about blocking funds in other contexts, please contact the OFAC Compliance Hotline.