• Deanna Clark-Esposito

It's Time to File OFAC's Annual Report of Blocked Property



The Reporting, Procedures and Penalties Regulations (RPPR) requires holders of blocked property 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.


For this Annual Report of Blocked Property (ARBP), 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 was previously blocked pursuant to a sanctions program that was terminated on or before June 30, 2022, is not considered blocked property, and should not be reported in the ARBP. Similarly, a restricted account of a person who is ordinarily a resident of 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.


Persons filing the 2022 ARBP are required to utilize spreadsheet form TD-F 90-22.50. Completed forms should be filed through the OFAC Reporting System (ORS). Failure to submit a required ARBP by September 30 constitutes a violation of the RPPR. Click here to view OFAC’s Guidance on Filing the Annual Report of Blocked Property for additional guidance.


Do you need help with your filing? Have other questions? Do not hesitate to contact us for assistance.


Ready to Learn More About CBP, OFAC,

BIS, and FDA? - for free! Details below.


We have dozens (literally!) of videos in our educational library on our You Tube channel related to importing, exporting, US Customs, BIS, OFAC, 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 contact@clarkespositolaw.com.



0 comments