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.