By John Foster for the GC Elite.
U.S. persons holding blocked property as of June 30 must file the 2026 Annual Report of Blocked Property with the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) by September 30. OFAC states that failure to file by that date constitutes a violation of the Reporting, Procedures and Penalties Regulations.
The form asks for something easy to overlook. For each asset listed, it asks for the identification number assigned to the initial report filed when the property was first blocked, if that report was submitted through OFAC’s reporting system. A company that characterised a stopped payment incorrectly earlier in the year will learn that this month, while assembling a filing that assumes the characterisation was right.
A person subject to U.S. jurisdiction that blocks property or rejects a transaction under U.S. sanctions must report the action to OFAC within 10 business days, measured from the date the property becomes blocked or the transaction is rejected. But blocking and rejection are not interchangeable.
Your company may have stopped the payment, or its funds may be sitting at an institution that will not explain why. The first task is to identify what happened. The answer determines the reporting obligation, the available procedure for obtaining release, and the party that can pursue it.
