Filing Reports with OFAC

Reports on blocked property and rejected transactions must be submitted to OFAC through the OFAC Reporting System (ORS) within 10 business days of the date of the action. These reports must include copies of relevant documents that support the information provided in the reports. Examples of supporting documentation include payment or transfer instructions, checks, letters of credit, bills of lading, invoices, or any other pertinent documentation. For more information on requirements for reports on blocked property and rejected transactions, see 31 CFR §§ 501.603 and 501.604, respectively. For additional details on reporting, and to register for access to the ORS, please see the OFAC Reporting System page on OFAC's website.

Holders of blocked property are also required to submit to OFAC annual reports on blocked property. (For more information on Annual Reports of Blocked Property, see FAQ 50.)

Date Updated: October 26, 2026

Yes. U.S. persons holding blocked property as of June 30 of the current year must submit an Annual Report of Blocked Property to OFAC no later than September 30 of the same year. Filers are required to use the Annual Report of Blocked Property spreadsheet form (TD F 90-22.50) and submit completed forms through the OFAC Reporting System (ORS). To access the required form or for additional guidance on filing annual reports of blocked property, please see the OFAC Reporting System page on OFAC's website.

Date Updated: October 26, 2026

OFAC expects U.S. persons and persons otherwise subject to U.S. jurisdiction to provide all information required by Section 501.604(b) of the RPPR​ that is in the filer’s possession in a rejected transaction report, and generally does not expect reporters to seek further information from their counterparty solely to obtain additional information required to be reported under Section 501.604(b). However, OFAC would expect at a minimum that all rejected transaction reports include required information that is applicable in all reject scenarios (e.g., information regarding the submitter of the report, the date the transaction was rejected, the legal authority or authorities under which the transaction was rejected, and any relevant documentation received in connection with the transaction).

If you have blocked and reported property due to mistaken identity or typographical or similar errors, you may unblock such property and file an unblocking report with OFAC consistent with the procedures described in 31 CFR 501.603(b)(3).  With respect to the information described in 31 CFR 501.603(b)(3)(ii)(F), the reporting person can cite FAQ 1196 in their unblocking report to indicate that the property was released due to mistaken identity or typographical errors, rather than an OFAC authorization like a general or specific license.  Please note, unblocking property in which a blocked person does in fact have an interest without authorization from OFAC could expose U.S. persons to civil penalties.

Alternatively, you may seek to have such property unblocked pursuant to the administrative procedures detailed at 31 CFR 501.806, known as a "Compliance Release."

OFAC strongly encourages organizations subject to U.S. jurisdiction to develop risk-based sanctions compliance programs that allow for the proper evaluation and adjudication of potential name matches to blocked persons. Organizations should not use the Compliance Release process as a substitute for internal controls to mitigate the risk of transactions or dealings in blocked property. 

Organizations should not request a Compliance Release in situations in which property was correctly blocked, but the status of the property has subsequently changed (e.g., a change in the portion of ownership by a blocked person).  In such scenarios, organizations should apply for a specific license. The Compliance Release process is solely for cases of mistaken identity or typographical or similar error, in which there was never a blockable interest in the subject property (e.g., a name match to a blocked person that the reporting organization later determines, with reliable supporting evidence, to be a false positive). Please note neither a specific license nor a Compliance Release is required to unblock property when a person is delisted from the Specially Designated Nationals and Blocked Persons List.

The Compliance Release process is only available to the organization who blocked the property; thus, if a financial institution or other organization has blocked your property and you are requesting that the property be unblocked, you should engage directly with the financial institution or other organization that blocked your property in cases of mistaken identity or apply for a specific license.

Organizations must retain records as related to the transactions described above. See 31 CFR 501.601 and 31 CFR 501.602 of the Reporting, Procedures and Penalties Regulations for applicable recordkeeping and reporting requirements.