31 C.F.R. § 501.603 of the Reporting, Procedures and Penalties Regulations (RPPR) requires U.S. persons holding blocked property as of June 30 of the current year to file an Annual Report of Blocked Property (ARBP) with the Office of Foreign Assets Control (OFAC) by September 30. Persons that did not hold blocked property as of June 30 do not need to file an ARBP.
Please note that the term blocked property only applies to property that is blocked pursuant to OFAC regulations. Property that was unblocked by an OFAC general or specific license, or that was previously blocked pursuant to a sanctions program that was terminated on or before June 30, 2026, is not considered blocked property, and should not be included in the ARBP.
Similarly, a restricted account of a person ordinarily resident in Iran is not blocked property and should not be reported to OFAC in the ARBP, unless a person whose property and interests in property are blocked pursuant to an applicable sanctions authority has an interest in the account.
Persons filing the 2026 ARBP must use spreadsheet form TD-F 90-22.50 and submit the completed form through the OFAC Reporting System (ORS). Failure to file the ARBP by September 30 constitutes a violation of the RPPR.
For additional information, please review OFAC's Guidance on Filing the 2026 Annual Report of Blocked Property.