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Don't forget to file blocked property report

OFAC has posted a reminder to file the 2020 Annual Report of Blocked Property (ARBP).

The Reporting, Procedures and Penalties Regulations (RPPR) require holders of blocked property to provide OFAC with a comprehensive list of all blocked property held as of June 30 of the current year by September 30 (no report is required if no blocked property is held on June 30).

The term "blocked property" only applies to property that is blocked under OFAC regulations. Property that was unblocked by an OFAC general or specific license or was previously blocked pursuant to a sanctions program that was terminated on or before June 30, 2020, is not considered blocked property, and should not be reported in the ARBP. 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.

Failure to submit a required ARBP by September 30 constitutes a violation of the RPPR. For more information see OFAC's Guidance on Filing the Annual Report of Blocked Property.

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