All U.S. persons and persons otherwise subject to U.S. jurisdiction, not only U.S. financial institutions, holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2024.

This report is pursuant to 31 C.F.R. §§ 501.603 of the Reporting, Procedures and Penalties Regulations (RPPR). This report must include all blocked property held as of June 30, 2024, and must be filed by September 30, 2024. Persons filing the 2024 report 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.

What Is Blocked Property?

All property and interests in property of any person designated by the Office of Foreign Assets Control (OFAC) to the Specially Designated Nationals and Blocked Entities List (SDN) or any person owned 50% or greater by an SDN entity that is in the United States, comes within the United States or comes within the possession and control of U.S. persons is blocked. Property of persons subject to certain other sanctions may also be blocked under the terms of the sanctions. U.S. persons are prohibited from directly or indirectly dealing in or with blocked property. Blocked property and interests in property is defined broadly to include not only tangible and intangible property but also accounts payable, invoices, contracts and other intangible items in which a blocked person holds an interest.

What Does Not Have to Be Reported?

OFAC notes that the following property should not be reported:

  • Property that has been unblocked by general or specific OFAC license is not blocked property.
  • Property that has been unblocked because the blocked person originally associated with the property was no longer blocked before July 1, 2023.
  • Property that has been unblocked as a result of an OFAC sanctions program being terminated (e.g., 31 C.F.R. part 543 (Côte d’Ivoire)) and is not currently blocked under any active sanctions program administered by OFAC.
  • Restricted “Iranian accounts,” as defined in OFAC’s regulations, should not be reported to OFAC on the annual report unless they are otherwise blocked.

For additional information on preparing this annual report, see OFAC’s Guidance on Filing the ARBP.

Posted in OFAC, Sanctions
Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Read more about Francesca M.S. Guerrero
Show more Show less
Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Read more about Samir D. Varma
Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Read more about Scott E. Diamond**
Show more Show less
Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.

*Licensed in MO only, not IL; limited to federal practice only.

Read more about Kristina Shcheglazova*Kristina's Linkedin Profile
Show more Show less
Related Posts
OFAC Amends Russia General License 55 Relating to the Sakhalin-2 Oil and Gas Project
June 20, 2025
Treasury Relaxes U.S. Economic Sanctions on Syria
May 27, 2025
OFAC Extends Winding Down Deadline of Venezuela General License 41
March 25, 2025