Regulatory Filing

2nd, 3rd and 4th Quarter FY2018 Reports for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA)

OFAC has released Quarterly Reports of Licensing Activities pursuant to Section 906(b) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by the Treasury Department’s Office of Foreign Assets Control (OFAC) under Section 906(a)(1) of the TSRA from January through September 2018.  Under the procedures established in its TSRA-related regulations, OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran and Sudan under the specific licensing regime set forth in Section 906 of the TSRA.

Links:

OFAC Notice

TSRA Reports for FY2018 – Q2, Q3, Q4

Final reminder: frozen assets reporting 2019

OFSI is conducting its annual frozen assets review. If you hold or control funds or economic resources belonging to, owned, held, or controlled by a designated person you are required to submit a report to the Treasury’s OFSI by Friday 11 October 2019.

Your report should include details of all funds or economic resources frozen in the UK as well as those overseas where these funds or economic resources are subject to UK financial sanctions legislation. Your report to OFSI should include the value of all such assets as of close of business on Monday 30 September 2019.

All completed reports should be emailed to ofsi@hmtreasury.gov.uk using the template on the GOV.UK website.

Please ensure that any changes to previous frozen asset reporting submissions are clearly identified and explained.

If you have already submitted your return, or have no information to report, please ignore this email.

Link:

OFSI Notice

Reminder: frozen assets reporting 2019

OFSI is conducting its annual frozen assets review. If you hold or control funds or economic resources belonging to, owned, held, or controlled by a designated person you are required to submit a report to the Treasury’s OFSI by Friday 11 October 2019.

Your report should include details of all funds or economic resources frozen in the UK as well as those overseas where these funds or economic resources are subject to UK financial sanctions legislation. Your report to OFSI should include the value of all such assets as of close of business on Monday 30 September 2019.

All completed reports should be emailed to ofsi@hmtreasury.gov.uk using the template on the GOV.UK website.

Please ensure that any changes to previous frozen asset reporting submissions are clearly identified and explained.

If you have already submitted your return, or have no information to report, please ignore this email.

For further information and to read the full notice

Link:

OFSI Frozen Assets Reporting Notice (September 5)

Reminder for the Annual Report of Blocked Property

On July 1, 2019, the Office of Foreign Assets Control (OFAC) issued a recent action notice, reminding holders of property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations (C.F.R.) of the requirement to provide OFAC with an Annual Report of Blocked Property (ARBP).  Persons subject to this reporting requirement must submit a comprehensive report, as outlined in 31 C.F.R. § 501.603, of all blocked property held as of June 30 of the current year by September 30.    

The annual reports must be filed using the mandatory spreadsheet form TD F 90-22.50, which is available on OFAC’s Reporting and License Application Forms webpage.  Please send the completed form to OFACReport@treasury.gov.  Failure to submit a required report by September 30 constitutes a violation of the Reporting, Procedures and Penalties Regulations, 31 C.F.R. part 501.  

 

For more information, click here to view OFAC’s Guidance on Filing the ARBP.

Link:

OFAC Notice

The numbers still aren’t enormous – 70,000 GBP total has been frozen under the ISIL/Al-Qaida regime, 18,000 under EU Reg 2580/2001 and 9,000 under TAFA. There were 45 total accounts frozen as of the end of the quarter, and only 2 new designations (both ISIL/AL-Qaida) and 4 delistings (also all ISIL/Al-Qaida) this quarter. There was one TAFA renewal.

Link:

April-June 2019 TAFA Report

Eighth Biennial Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA)

OFAC has released a Biennial Report of Licensing Activities pursuant to Section 906(c) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by the Treasury Department’s Office of Foreign Assets Control (OFAC) under Section 906(a)(1) of the TSRA from October 2014 through September 2016.  Under the procedures established in its TSRA-related regulations, OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran and Sudan under the specific licensing regime set forth in Section 906 of the TSRA.

Links:

OFAC Notice

TSRA Biennial Report

This is OFAC’s 27th “Annual Report to the Congress on Assets in the United States Relating to Terrorist Countries and Organizations Engaged in International Terrorism” – a mouthful, I know.

Some highlights:

  • $46.181 million in blocked terrorist organization assets, up from $43.606 million in 2017
  • Biggest increases in this group – Hizballah blocked assets increased from $9.814 million to $11.601 million, Hamas went from $1.143 million to $1.364 million, the IRGC-Quds Force increased from $14.491 million to $14.989 million, ISIL went from $251,613 to $657,689, Lashkar-e Tayyiba increased from $218,639 to $397,774, and the Taliban increased from $10,728 to $206,805.
  • State Sponsors of Terrorism have $216.83 million in blocked funds, up from $201.53 million in 2017
  • Of that increase, the overwhelming bulk is due to North Korea (almost $11 million), with Iran ($2.9 million) and Syria ($1.4 million) making up the rest
  • State Sponsors of terrorism own a bit of real estate: Syria owns 4 properties, Iran 11, and Bank Melli indirectly has an ownership interest in a NY building

Link:

Calendar Year 2018 Terrorist Assets Report