Key Notes:
- U.S. sanctions regulations require persons subject to U.S. jurisdiction to file initial and annual reports on blocked property and rejected transactions with OFAC.
- Annual reports of property blocked from July 1, 2020 to June 30, 2021 must be submitted by September 30, 2021.
- There is no annual reporting requirement for rejected transactions.
On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Reporting, Procedures and Penalties Regulations, 31 C.F.R. Part 501 (RPPR), to require all U.S. persons and persons otherwise subject to U.S. jurisdiction, not only U.S. financial institutions as previously required, to file certain reports on blocked property and rejected transactions pursuant to RPPR §§ 501.603 and 604.
Any such person holding property that became blocked between July 1, 2020 and June 30, 2021 must file an annual report with OFAC in compliance with 31 C.F.R. § 501.603(b)(2)(i)–(iii) by September 30, 2021.