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 Reminder for the Annual Report of Blocked Property

​31 C.F.R. § 501.603 requires financial institutions to provide the Office of Foreign Assets Control (OFAC) with a comprehensive list of all blocked property held as of June 30 of the current year by September 30.  Please note that the term blocked property only applies to property that is blocked pursuant to OFAC regulations.  Property that has been unblocked by general or specific license, but which has not yet been returned to the owner, is not blocked property, and should not be reported to OFAC in the Annual Report of Blocked Property (ARBP).  This includes, for example, property of the Government of Sudan unblocked as a result of the January 17, 2017 issuance of the general license found at 31 C.F.R. § 538.540 which may remain in the possession of a financial institution.  Similarly, a restricted account of a person ordinarily resident in Iran is not blocked, and should not be reported to OFAC in the ARBP, unless there is an interest in the account of a person whose property and interests in property are blocked pursuant to an applicable sanctions authority.

The annual reports must be filed using Form TD F 90-22.50, Annual Report of Blocked Property.  Please send completed forms to  For more information, click here to view OFAC’s Guidance on Filing the Annual Report of Blocked Property.

Last Updated: 6/30/2017 10:03 AM