Reminder for the Annual Report of Blocked Property

31 C.F.R. § 501.603 requires persons holding property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations to provide the Office of Foreign Assets Control (OFAC) with a comprehensive list of all blocked property held as of June 30 of the current year by September 30.  Persons that do not hold blocked property as of June 30 do not need to file an Annual Report of Blocked Property (ARBP).  Please note that the term blocked property only applies to property that is blocked pursuant to OFAC regulations.  Property that has been unblocked by a general or specific license, but that has not been returned to its owner, is not blocked property, and should not be reported to OFAC in the ARBP.  This includes, for example, property of the Government of Sudan unblocked as a result of the January 17, 2017 issuance of the general license found at 31 C.F.R. § 538.540.  Similarly, a restricted account of a person ordinarily resident in Iran is not blocked, and should not be reported to OFAC in the ARBP, unless there is an interest in the account of a person whose property and interests in property are blocked pursuant to an applicable sanctions authority.

 

The annual reports must be filed using Form TD F 90-22.50, Annual Report of Blocked Property.  If your institution holds 20 or more blocked accounts, OFAC recommends, but does not require, supplementing Part B of your ARBP with a spreadsheet along with your completed form.  Please send completed forms to OFACReport@treasury.gov.  Failure to submit a required report by September 30 constitutes a violation of 31 C.F.R. Part 501 (“Reporting, Procedures and Penalties Regulations”).  OFAC’s Guidance on Filing the Annual Report of Blocked Property for additional guidance.