31 CFR §501.603 — Reports of blocked, unblocked, or transferred blocked property

ofac-31cfr-501-603

OFAC reporting rule. U.S. persons (and persons subject to U.S. jurisdiction under part 515) who hold, unblock, or transfer property blocked pursuant to 31 CFR chapter V must file initial blocking reports within 10 business days, annual reports by September 30 covering property held as of June 30, and unblock / transfer reports within 10 business days, generally through the OFAC Reporting System (ORS).

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source:
  type: regulation
  id: ofac-31cfr-501.603
  authority: 31 CFR §501.603 — Reports of blocked, unblocked, or transferred blocked property
  description: |
    OFAC reporting rule. U.S. persons (and persons subject to U.S.
    jurisdiction under part 515) who hold, unblock, or transfer
    property blocked pursuant to 31 CFR chapter V must file initial
    blocking reports within 10 business days, annual reports by
    September 30 covering property held as of June 30, and unblock /
    transfer reports within 10 business days, generally through the
    OFAC Reporting System (ORS).
obligations:
  - id: ofac-31cfr-501.603-b1-initial-blocking-10-day
    canonical_id: ofac-31cfr-501.603-b1-initial-blocking-10-day
    section: 31 CFR §501.603(b)(1)(i) — Initial blocking reports within 10 business days
    description: |
      Where [LENDER] (as a U.S. person, including a financial institution)
      holds property blocked pursuant to 31 CFR chapter V, [LENDER] shall
      file an initial blocking report with OFAC within 10 business days
      from the date that property becomes blocked, including all required
      contact, transaction, target, property, blocking-date, value, action,
      and legal-authority information under §501.603(b)(1)(ii).
    type: do
    audit_question: For every property blocked by [LENDER] under any OFAC sanctions program, can [LENDER] evidence an initial blocking report filed with OFAC within 10 business days of the blocking date, with the §501.603(b)(1)(ii)(A)–(I) required content?
    program_review: Do the P&Ps ensure that whenever property becomes blocked under any OFAC program, [LENDER] files an initial blocking report with OFAC within 10 business days, with the §501.603(b)(1)(ii)(A)-(I) required content?
    file_review: For each blocking event, confirm an initial blocking report was filed within 10 business days with the required (A)-(I) content.
    judgment: false
    feeds: []
    workflow_phase: origination
    owner_role: compliance_officer
    secondary_owner_role: bsa_aml_officer
    cadence: per-blocking-event
    consequence: ''
    tags:
      - round-b
      - regulator-direct
      - ofac
      - treasury
      - sanctions
      - blocked-property
      - initial-blocking-report
      - 10-business-days
      - promoted
    primary_source:
      tier: 1
      authority: 31 CFR §501.603(b)(1)(i)
      source_class: ofac-treasury
      source_url: https://www.law.cornell.edu/cfr/text/31/501.603
      snapshot_id: 8de15e095e630af6
      fetched_at: '2026-05-22T11:34:29Z'
      content_hash: sha256:3162982a0e7fb6605f8ef5e32a16ec5cf8b521ec2a68bd2964bc61467a6d8477
      paragraph_quote: (b) What must be reported —(1) Initial blocking reports —(i) When reports are due. Reports shall be filed within 10 business days from the date that property becomes blocked.
      drafter_attestation: |
        Copied verbatim from snapshot 8de15e095e630af6 (content.txt) at
        2026-05-22T11:40Z. Substring is the §501.603(b)(1)(i) timing rule;
        the (b)(1)(ii) required-information subparagraphs (A)–(I) are
        paraphrased in description.
    promoted_at: '2026-05-22T12:13:34+00:00'
    promoted_from: ofac-31cfr-501.603-roundb-v1.yaml
  - id: ofac-31cfr-501.603-b2-annual-blocked-property-report
    canonical_id: ofac-31cfr-501.603-b2-annual-blocked-property-report
    section: 31 CFR §501.603(b)(2)(i) — Annual report of blocked property by September 30
    description: |
      [LENDER] shall file annually with OFAC a report on all property
      blocked pursuant to 31 CFR chapter V and held as of June 30 of the
      current year. The annual report shall be filed no later than
      September 30 and shall include the §501.603(b)(2)(ii)(A)–(G)
      required content (holder identity, account/item count, target,
      property description, blocking date, June 30 value in U.S. dollars,
      and legal authority).
    type: do
    audit_question: For each calendar year, can [LENDER] evidence an annual blocked-property report filed with OFAC by September 30, covering all property blocked under 31 CFR chapter V held as of June 30, with the §501.603(b)(2)(ii) required content?
    program_review: Do the P&Ps ensure an annual blocked-property report covering all property blocked and held as of June 30 is filed with OFAC by September 30, with the §501.603(b)(2)(ii)(A)-(G) required content?
    file_review: For each year with blocked property held as of June 30, confirm the annual report was filed by September 30 with the required content.
    judgment: false
    feeds: []
    workflow_phase: origination
    owner_role: compliance_officer
    secondary_owner_role: bsa_aml_officer
    cadence: annual
    consequence: ''
    tags:
      - round-b
      - regulator-direct
      - ofac
      - treasury
      - sanctions
      - blocked-property
      - annual-report
      - promoted
    primary_source:
      tier: 1
      authority: 31 CFR §501.603(b)(2)(i)
      source_class: ofac-treasury
      source_url: https://www.law.cornell.edu/cfr/text/31/501.603
      snapshot_id: 8de15e095e630af6
      fetched_at: '2026-05-22T11:34:29Z'
      content_hash: sha256:3162982a0e7fb6605f8ef5e32a16ec5cf8b521ec2a68bd2964bc61467a6d8477
      paragraph_quote: (2) Annual reports of blocked property —(i) When reports are due. A report on all blocked property held as of June 30 of the current year shall be filed annually by September 30.
      drafter_attestation: |
        Copied verbatim from snapshot 8de15e095e630af6 (content.txt) at
        2026-05-22T11:40Z. Substring is the §501.603(b)(2)(i) operative
        timing rule; (b)(2)(ii)(A)–(G) required-content subparagraphs are
        paraphrased in description.
    promoted_at: '2026-05-22T12:13:34+00:00'
    promoted_from: ofac-31cfr-501.603-roundb-v1.yaml
  - id: ofac-31cfr-501.603-b3-unblock-transfer-10-day
    canonical_id: ofac-31cfr-501.603-b3-unblock-transfer-10-day
    section: 31 CFR §501.603(b)(3)(i) — Reports on unblocked or transferred blocked property within 10 business days
    description: |
      Except as provided in §501.603(b)(3)(i)(A)–(D), [LENDER] shall
      submit reports to OFAC within 10 business days from the date
      blocked property is unblocked or transferred. The reports shall
      include the §501.603(b)(3)(ii)(A)–(G) required content (holder
      identity prior to release, target, property description, unblock
      date, value in U.S. dollars, legal authority, and a copy of the
      original blocking report).
    type: do
    audit_question: For every unblock or transfer of OFAC-blocked property by [LENDER] not covered by the (b)(3)(i)(A)–(D) carve-outs, can [LENDER] evidence a §501.603(b)(3) report filed with OFAC within 10 business days of the unblock/transfer date?
    program_review: Do the P&Ps ensure that, except for the (b)(3)(i)(A)-(D) carve-outs, [LENDER] files a §501.603(b)(3) report with OFAC within 10 business days of any unblock or transfer of blocked property, with the (b)(3)(ii)(A)-(G) required content (including a copy of the original blocking report)?
    file_review: For sampled unblock/transfer events not within the carve-outs, confirm a report filed within 10 business days with the required content.
    judgment: false
    feeds: []
    workflow_phase: origination
    owner_role: compliance_officer
    secondary_owner_role: bsa_aml_officer
    cadence: per-unblock-or-transfer
    consequence: ''
    tags:
      - round-b
      - regulator-direct
      - ofac
      - treasury
      - sanctions
      - blocked-property
      - unblock-report
      - 10-business-days
      - promoted
    primary_source:
      tier: 1
      authority: 31 CFR §501.603(b)(3)(i)
      source_class: ofac-treasury
      source_url: https://www.law.cornell.edu/cfr/text/31/501.603
      snapshot_id: 8de15e095e630af6
      fetched_at: '2026-05-22T11:34:29Z'
      content_hash: sha256:3162982a0e7fb6605f8ef5e32a16ec5cf8b521ec2a68bd2964bc61467a6d8477
      paragraph_quote: (3) Reports of blocked property that is unblocked or transferred —(i) When reports are due. Except as provided in paragraphs (b)(3)(i)(A) through (D) of this section, reports shall be submitted to OFAC within 10 business days from the date blocked property is unblocked or transferred.
      drafter_attestation: |
        Copied verbatim from snapshot 8de15e095e630af6 (content.txt) at
        2026-05-22T11:40Z. Substring is the §501.603(b)(3)(i) timing rule;
        (b)(3)(i)(A)–(D) carve-outs and (b)(3)(ii) content subparagraphs
        are paraphrased in description.
    promoted_at: '2026-05-22T12:13:34+00:00'
    promoted_from: ofac-31cfr-501.603-roundb-v1.yaml
_promotion_history:
  - promoted_at: '2026-05-22T12:13:34+00:00'
    candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\_round_b_drafts\ofac-31cfr-501.603-roundb-v1.yaml
    candidates_promoted: 3
    candidates_skipped_existing: 0

Verbatim regulatory text (3)

Verbatim provisions from 31 CFR §501.603 — Reports of blocked, unblocked, or transferred blocked property — each quote is a verified substring of the regulator-published source snapshot, not retyped. Quoted for reference; this is not legal advice. The operational layer (P&P updates, prompts) lives in the regulation update kits.

31 CFR §501.603(b)(1)(i) — Initial blocking reports within 10 business days

(b) What must be reported —(1) Initial blocking reports —(i) When reports are due. Reports shall be filed within 10 business days from the date that property becomes blocked.

Source: 31 CFR §501.603(b)(1)(i) · source URL · snapshot 8de15e095e630af6

31 CFR §501.603(b)(2)(i) — Annual report of blocked property by September 30

(2) Annual reports of blocked property —(i) When reports are due. A report on all blocked property held as of June 30 of the current year shall be filed annually by September 30.

Source: 31 CFR §501.603(b)(2)(i) · source URL · snapshot 8de15e095e630af6

31 CFR §501.603(b)(3)(i) — Reports on unblocked or transferred blocked property within 10 business days

(3) Reports of blocked property that is unblocked or transferred —(i) When reports are due. Except as provided in paragraphs (b)(3)(i)(A) through (D) of this section, reports shall be submitted to OFAC within 10 business days from the date blocked property is unblocked or transferred.

Source: 31 CFR §501.603(b)(3)(i) · source URL · snapshot 8de15e095e630af6