On July 6, 2021, 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 the Reporting, Procedures and Penalties Regulations (RPPR), of all blocked property held as of June 30 of the current year by September 30.   

The annual reports must be filed using the mandatory spreadsheet form TD F 90-22.50.  Completed forms should be sent to or 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. 

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Author: Editor
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