On September 22, 2023, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued its “Reminder to file your 2023 annual report of Blocked Property,” noting that entities or persons subject to the reporting requirement must submit a comprehensive report of all blocked property held as of June 30, 2023, by September 30, 2023, which is a Sunday. We are encouraging our clients subject to the reporting requirements to file a report no later than the close of business this Friday, September 29.
Persons and entities subject to the reporting requirement include all U.S. persons (or persons subject to U.S. jurisdiction) who have or have had in their possession or control any “blocked property,” including, but not limited to, financial institutions that receive and block payments or transfers.
“Blocked property,” includes property subject to any U.S. sanctions program and the Specially Designated Nationals (“SDN”) list administered by OFAC.
Since Russia invaded the Ukraine in February 2022, we have seen unprecedented activity from OFAC. The U.S. has successively imposed sweeping sanctions on Russia and Belarus, and OFAC has added hundreds of individuals and entities to its SDN List. Between January 1, 2023 and June 30, 2023 alone, OFAC updated its SDN list more than 100 times. As such, we expect a large number of U.S. persons will be required to file the 2023 annual reports.
Annual reports must be filed using the mandatory spreadsheet form TD-F 90-22.50. Completed forms should be sent to ofacr[email protected] or filed through the OFAC Reporting System (“ORS”). 2023 filing guidance from OFAC is available here. As always, if you have any questions about OFAC’s requirements, Volkov Law is here to help.