On September 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued its “Reminder to File the 2025 Annual Report of Blocked Property.” Entities or persons subject to the reporting requirement under 31 C.F.R. § 501.603 of the Reporting, Procedures and Penalties Regulations (“RPPR”) must submit a comprehensive report of all blocked property held as of June 20, 2025. This report must be submitted by September 30, 2025.
Under this reporting requirement, blocked property includes any property subject to any U.S. sanctions program, such as property where an entity on the Specially Designated Nationals List (“SDN List”) holds an interest. Blocked property does not include any property that was unblocked for any reason, such as pursuant to a General License or a Specific License.
To complete and submit a report, all submissions should be made with the mandatory TD-F90-22.50 spreadsheet form. Completed forms should be filed through the OFAC Reporting System (ORS). I am here to help if you have any questions about the form and OFAC’s requirements.
