top of page
  • clarkespositolaw

Don’t Miss the Deadline: Filing the 2023 ARBP for Blocked Property

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) plays a crucial role in enforcing economic and trade sanctions imposed by the United States government. As part of its oversight responsibilities, OFAC requires holders of blocked property to submit an Annual Report of Blocked Property (ARBP) to ensure compliance with relevant regulations. On July 3rd, the U.S. Department of the Treasury issued a reminder regarding the filing of the 2023 ARBP.

Filing Requirements and Deadlines

Under 31 C.F.R. § 501.603, all individuals and entities that hold blocked property as of June 30 must provide OFAC with a comprehensive list of the blocked property by September 30. It is important to note that if no blocked property is held as of June 30, there is no obligation to file an ARBP. The reporting requirement specifically pertains to property blocked according to OFAC regulations.

Exclusions from Reporting

It's crucial to understand the exclusions from reporting to ensure accurate compliance. Property that has been unblocked by an OFAC general or specific license or was previously blocked under a sanctions program that ended on or before June 30, 2023, is not considered blocked property and should not be included in the ARBP. Similarly, restricted accounts of individuals ordinarily residing in Iran should not be reported unless there is an interest in the account of an individual whose property and interests are blocked under applicable sanctions.

Reporting Procedure and Formats

To streamline the reporting process, OFAC mandates the use of spreadsheet form TD-F 90-22.50 for the 2023 ARBP filing. Completed forms can be submitted through the OFAC Reporting System (ORS) or emailed to It is essential to ensure the accurate completion of the form and adherence to the required format to avoid any potential issues during submission.

Consequences of Non-compliance

Failure to submit the required ARBP by the September 30, 2023, deadline constitutes a violation of the Reporting, Procedures, and Penalties Regulations (RPPR). Non-compliance with OFAC regulations can have serious consequences, including financial penalties, reputational damage, and legal repercussions. Therefore, it is crucial for all affected individuals and entities to take this filing requirement seriously and submit the ARBP within the stipulated time frame.

Navigating the complexities of OFAC regulations and ensuring compliance with the ARBP filing requirements can be a daunting task. We understand the importance of meeting deadlines and adhering to regulatory obligations. Our experienced team of legal professionals specializes in OFAC compliance and can assist you in preparing and filing your 2023 ARBP accurately and on time.

Have questions or need assistance? Give our office a call today at (917) 546-6997, we would be happy to speak with you.

Ready to Learn More About CBP, OFAC,

BIS, FWS, and FDA?

We have dozens (literally!) of videos in our educational library on our YouTube channel related to importing, exporting, US Customs, BIS, OFAC, FWS, FDA, NFTs, and so much more. Subscribe to our channel now to stay up to date on the latest on these topics!

Our law firm helps growing companies who import and export comply with government regulations. We love what we do and we take our oath of confidentiality over your matters very seriously. How much? Watch this video to learn about it. CLICK HERE

Wondering "why should you have an attorney on your side?" Click here to watch one of our attorneys, Susan Steinman, break down the critical benefits as to why you want to have one on your side - whether you hire us to help you or another law firm.

Have questions? We are determined to help you.

We listen carefully to clients to ensure our understanding of the legal issues at hand, their factual context, and any limitations that might impact a chosen strategy. Feel free to connect with us using the contact form at the bottom of the Home page or send us an email at


bottom of page