Each year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) requires all holders of blocked property to submit an Annual Report of Blocked Property (“ARBP”) setting forth all blocked property held as of June 30 of the current year.

The 2024 ARBP is due by September 30, 2024. The ARBP must be prepared using OFAC’s specific ARBP Form and the completed form should be submitted through the new OFAC Reporting System (“ORS”).

Failure to submit a required ARBP by the September 30, 2024 deadline constitutes a violation of OFAC’s regulations.

If you have any questions regarding the matters covered in this e-mail, please contact Bruce Paulsen (212) 574-1533, Brian Maloney (212) 574-1448, Carmella O’Hanlon (212) 574-1351, or your primary Seward & Kissel attorney.