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  • Writer's pictureDeanna Clark

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 OFACreport@treasury.gov. 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.

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