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OFAC UPDATE: Reminder for the Annual Report of Blocked Property

On July 1, 2020, the Office of Foreign Assets Control (OFAC) issued a recent action notice, reminding holders of property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations (C.F.R.) of the requirement to provide OFAC with an Annual Report of Blocked Property (ARBP).  Persons subject to this reporting requirement must submit a comprehensive report, as outlined in 31 C.F.R. § 501.603, of all blocked property held as of June 30th of the current year by September 30, 2020.   

The annual reports must be filed using the mandatory spreadsheet form TD F 90-22.50.  and once completed sent to  Failure to submit a required report by September 30 constitutes a violation of the Reporting, Procedures and Penalties Regulations, 31 C.F.R. part 501. 

It is important to note that on June 21, 2019, OFAC published an amendment to the Reporting, Procedures and Penalties Regulations, 31 C.F.R. part 501 (RPPR).

This rule added now requires for submitters of the ARBP who maintain blocked funds in omnibus accounts to include a disaggregated list showing each blocked asset contained within the omnibus account. Additionally, this rule also added a new requirement to include the associated sanctions target for each blocked property record included within the ARBP.

OFAC has provided a detailed guidance document with general instructions and tips about filing the ARBP which can be found here.

Information provided by the U.S. Office of Foreign Assets Control.

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