Although we have none, our audits are asking us to have procedures for monitoring blocked accounts. If the funds are in an interest bearing account, we place a hold on the account and report it to OFAC, what is left to do? Does anyone have any experience with this that they would like to share?

I would recommend having procedures to cover the following:

--Completion and submission to OFAC of the annual report of blocked accounts
--A periodic review of your list of blocked accounts to ensure that they remain in "blocked" status

You may also want to consider covering the following scenarios in your procedures:
--What course of action needs to be taken in the event your systems flag the "blocked" accounts as inactive or domant?
--Procedures for handling accounts held by Iranian persons that you have restricted pursuant to OFAC's Iran sanctions but which are technically not considered "blocked". These are not required to be listed on the annual report of blocked accounts, but you still need to prevent credit/debit activity from occurring through them while they are restricted.