The deadline to file OFAC’s Annual Report of Blocked Property (“ARBP”) is approaching fast.  All “U.S. persons” — including U.S. financial institutions, companies, and individuals — who hold property blocked pursuant to any OFAC sanctions program should take a moment to assess their reporting obligations, as set forth in 31 C.F.R. § 501.603.

This annual reporting obligation applies across all OFAC sanctions programs and covers a wide range of asset types — from bank accounts and wire transfers to securities, real estate, digital assets, and intangible property.

OFAC rules require all U.S. persons to report to OFAC by September 30, 2026, any blocked property they held as of June 30, 2026.

Who Must File an ARBP with OFAC?

• Any U.S. person holding blocked property as of June 30, 2026.  A “U.S. person” is typically defined to include United States citizens, permanent resident aliens, entities organized under the laws of the United States or any jurisdiction within the United States (including their foreign branches), and any person physically located in the United States. 
• With respect to property blocked under OFAC’s Cuban Asset Control Regulations, the reporting obligation also applies to “persons subject to the jurisdiction of the United States,” which has a similar definition but includes non-U.S. subsidiaries of U.S. entities.

What Constitutes “Blocked Property”?

• The term “blocked property” means property in any form, whether digital, physical, tangible or intangible, that is blocked pursuant to OFAC regulations.

What is Not Considered “Blocked Property” for the Purposes of the ARBP?

• Property that was unblocked or permitted to be transferred by an OFAC general or specific license, or that was previously blocked pursuant to a sanctions program that was terminated on or before June 30, 2026, unless the relevant specific or general license includes a condition requiring the submission of a separate unblocking report.
• Property that was unblocked pursuant to OFAC’s removal of a person from OFAC’s SDN List.
• Property that is subject to “reject” sanctions rather than blocking sanctions.  These prohibit transactions involving the property but do not require a U.S. person to immobilize and retain the property.
• Assets immobilized pursuant to Directive 4 of Executive Order 14024.

How to File an ARBP with OFAC

• Individuals or entities filing an ARBP with OFAC must use spreadsheet form TD-F 90-22.50 to make their reports. Please note that OFAC only accepts the most current version of the form (OMB No. 1505-0164).
• Guidance on filing the 2026 ARBP, including how to complete OFAC’s ARBP spreadsheet, may be found here.
• The ARBP must be submitted via the OFAC Reporting System (ORS).
• First-time ORS users should email OFACReport@treasury.gov to request registration instructions in advance of the deadline. Establishing an account usually takes 24 hours.  As a result, individuals or entities expecting to file an ARBP with OFAC may wish to request access credentials well before September 30th.

Common Issues with ARBPs

According to OFAC guidance, the most common reasons for OFAC to return an ARBP submission include:

• Incorrect ORS Report IDs;
• Missing or incomplete sanctions target information;
• Failure to explain the sanctions target’s property interests in the property listed on the ARBP; and
• Formatting changes to the Excel template (e.g., password-protecting the file) that prevent OFAC from reviewing the submission.

Crowell assists financial institutions, multinational enterprises, technology companies, startups, and individuals in filing ARBPs.  Please contact any of the authors with any questions about OFAC’s blocked property report requirements.