July 1, 2020

OFAC issues reminder to holders of blocked property regarding annual reporting requirements

On July 1, 2020, the US Department of the Treasury’s Office of Foreign Assets Control issued a reminder to all holders of blocked property, that they must provide OFAC with a comprehensive list of all blocked property held as of June 30, 2020, pursuant to 31 C.F.R. §501.603 of the Reporting, Procedures, and Penalties Regulations (RPPR).  The requirement to file a 2020 Annual Report of Blocked Property (ARBP) only apples to property that was blocked pursuant to an OFAC regulation or recent Executive Order that has not yet been implemented in the regulations.  According to OFAC guidelines, an ARBP filing is not required for any property that has been unblocked by an OFAC general or specific license on or before June 30, 2020, or unblocked by the termination of a sanctions program on or before June 30, 2020.  Furthermore, restricted “Iranian accounts” do not need to be reported to OFAC, unless the account belongs to a person whose property or interests in property is otherwise blocked.  OFAC reports that the deadline to file all ARBP documents is September 30, 2020, and failure to submit a required ARBP by this date will constitute a violation of the RPPR.

OFAC News Bulletin | OFAC Guidance on Filing 2020 ARBP