OFAC requires annual blocked property filings by September 30

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OFAC annual blocked property filing

Highlights

OFAC requires U.S. persons with blocked property as of June 30, 2026, to file the Annual Report of Blocked Property by September 30, 2026.
Entities must submit form TD-F 90-22.50 via the OFAC Reporting System, with late filings constituting violations of 31 C.F.R. § 501.603.
OFAC clarifies only assets currently blocked under its regulations count for the report, excluding previously unblocked or terminated sanction program property, reducing misreporting risk.

2026 filing rules and scope

As reported by the Office of Foreign Assets Control, 31 C.F.R. § 501.603 of the Reporting, Procedures and Penalties Regulations requires U.S. persons holding blocked property at June 30 of the current year to file an Annual Report of Blocked Property, or ARBP, by September 30.

Entities or individuals that do not hold blocked property as of June 30 do not need to file. OFAC says blocked property covers only assets blocked under its regulations, and excludes property unblocked through a general or specific license as well as property previously blocked under a sanctions program terminated on or before June 30, 2026.

A restricted account of a person ordinarily resident in Iran is also not treated as blocked property for ARBP purposes, unless a person whose property and interests in property are blocked under an applicable sanctions authority has an interest in that account.

Compliance process and sanctions impact

Filers of the 2026 ARBP must use spreadsheet form TD-F 90-22.50 and submit the completed form through the OFAC Reporting System, or ORS. OFAC says failure to file the report by September 30 constitutes a violation of the Reporting, Procedures and Penalties Regulations.

The reminder keeps compliance pressure on financial institutions and other U.S. persons handling sanctioned assets, as reporting obligations remain a core part of the U.S. sanctions enforcement framework. The guidance also narrows the reporting scope by clarifying which assets should not be included, reducing the risk of misreporting for firms managing restricted or previously unblocked property.

Our earlier coverage of Ireland’s review of exports from the Russian-owned Aughinish Alumina plant outlined how Dublin came under growing pressure to limit shipments to Russia amid calls for tougher EU sanctions. We noted that disputed export volumes and the plant’s ties to Rusal raised political and reputational risks during Ireland’s EU presidency, with options ranging from tighter oversight to more forceful intervention if the investigation supports stronger action.

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