OFAC Reporting Requirements

Who must report blocked property and rejected transactions to OFAC, the exact deadlines, what each report must contain, and where to file — per 31 CFR 501.603 and 501.604.

TL;DR

Four filings do most of the work: an initial blocked-property report within 10 business days of blocking, an annual blocked-property report by September 30, an unblocking/transfer report within 10 business days, and a rejected-transaction report within 10 business days. Initial and annual reports go through the OFAC Reporting System (ORS); unblocking and transfer reports go to OFACReport@treasury.gov or ORS. The obligations sit in 31 CFR 501.603 (blocked property) and 501.604 (rejected transactions).

Who must report

Any U.S. person holding, unblocking, or transferring property blocked under a sanctions program must file the blocked-property reports — including financial institutions that receive and block payments or transfers (31 CFR 501.603(a)(1)). A report may be filed on your behalf by an attorney or agent, but primary responsibility stays with the actual holder, transferrer, or releaser of the property (501.603(a)(2)). Filing a report about the same property by someone else does not excuse you, unless you actually know that report was filed.

On the rejection side, any U.S. person that rejects a transaction which is not blocked but whose processing would violate a sanctions provision must report it (31 CFR 501.604(a)). “Transaction” here covers wire transfers, trade finance, securities, checks, foreign exchange, and sales or purchases of goods or services (501.604(a)(3)).

The four deadlines

What a blocked-property report must contain

Initial reports under 501.603(b)(1)(ii) must include, at minimum:

• Name and address of the holder, plus a contact name, telephone number, and email address
• A description of the associated transaction: type, participants (customers, originators, beneficiaries, intermediary and correspondent banks) and their locations, and reference numbers and dates
• The sanctioned target(s) whose property is blocked, their location if known, and, if not evident, a narrative of the target’s interest in the property
• A description of the blocked property, its location, account numbers and account types
• The date the property was blocked
• The value in U.S. dollars — or an estimate; negative-balance items such as outstanding loans are reported as $0.00 with the amount owed in the narrative
• Any action taken with respect to the property (for example, depositing it into a blocked interest-bearing account)
• The legal authority for blocking: the sanctions program, the CFR part (e.g., 31 CFR part 515 or 544), an Executive order (e.g., E.O. 13224, E.O. 13599), or a statute — the generic term “SDN” alone is not sufficient
• Copies of payment or transfer instructions, checks, letters of credit, bills of lading, invoices, or other relevant documentation

Where to file

Initial blocked-property reports and annual reports must be filed electronically through the OFAC Reporting System (ORS) (501.603(d)(1)). Unblocking and transfer reports must be submitted by email to OFACReport@treasury.gov with the section number in the subject line, or through ORS (501.603(d)(2)). Rejected-transaction reports go through ORS as well (501.604(d)). If a submitter can evidence unique and extraordinary circumstances preventing electronic filing, OFAC may allow an alternative channel, but such requests carry a presumption of denial and must be granted in writing. A copy of every filed report must be retained for the submitter’s records.

When you do not file an unblocking report

Four cases are exempt under 501.603(b)(3)(i)(A)–(D): authorized debits to blocked accounts for normal service charges; authorized transfers between blocked accounts within the same financial institution; unblocking or transfer explicitly authorized by a specific or general license (unless the license itself requires a separate report); and unblocking driven by OFAC’s removal of a person from the SDN List.

Why the paper trail matters

Reports are not just administrative. They tell OFAC what your organization touched, when, and what it did about it. Complete, timely reports are evidence of an operating compliance program; gaps, late filings, or reports that never arrive suggest the opposite and compound whatever the underlying problem was.

How screening connects

Every screening result is a potential reporting event. A clean result is not reported. A flagged result that leads to a rejection or a block is. That means the screening system and the reporting process need to feed each other, so that nothing is frozen or refused without a corresponding record.

The agent payment angle

An AI agent that screens before it pays produces an automatic audit trail: each check, each ALLOW, each BLOCK. SanctionsAI’s protocol ends in a STAMP step, and its tools include dispute_open, giving a record that can feed a reporting workflow. Building that trail in from the start is far easier than reconstructing it after OFAC asks.

Sources: 31 CFR 501.603 and 501.604 as published in the Electronic Code of Federal Regulations (eCFR), current through amendments cited at 91 FR 46837 (July 27, 2026). Machine-readable source manifest: /data/ofac-reporting-requirements-sources.json. This page is general information, not legal advice.