Regulatory Reporting

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

The UK publishes a quarterly report about its counter-terrorism sanctions program – and the one for Q4 of 2018 (calendar) is out. Here are the highlights:

  • At the end of the quarter, 9,000 GBP was frozen under TAFA, 18,000 under EU Reg 2580/2001, and 70,000 under the ISIL/Al-Qaida regime (EU Reg 881/2002). These represent 6 TAFA accounts or payments, 3 for EC 2580/2001 and 36 for ISIL-AQ. One item was frozen during the quarter under ISIL-AQ.
  • There were 3 new ISIL-AQ designations during the quarter and one new one under EU Reg 2016/1686 .
  • There were 5 TAFA renewals during the quarter
  • Under the ISIL-AQ regime, 8 licenses were issued during the quarter. And there are still 4 active General Licenses.

Link:

TAFA October-December 2018 Report

Office of Financial Sanctions Implementation

 

Reminder: Frozen Assets Reporting (2018) 

 

This is a reminder that 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 12 October 2018.

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 Friday 28 September 2018.

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

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

Link:

OFSI Notice

Office of Financial Sanctions Implementation

 

Reminder: Frozen Assets Reporting (2018) 

 

This is a reminder that 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 Office of Financial Sanctions Implementation (OFSI) by Friday 12 October 2018.

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 Friday 28 September 2018.

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

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

 

The detailed notice from HM Treasury is below.

Link:

HMT Notice

Reminder for the Annual Report of Blocked Property

 
On July 2, 2018, OFAC issued a recent actions notice notifying persons holding property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations of the requirement, as outlined in 31 C.F.R. § 501.603, to provide OFAC with a comprehensive report on all blocked property held as of June 30 of the current year by September 30.  
 
The annual reports must be filed using Form TD F 90-22.50, Annual Report of Blocked Property (ARBP).  If your institution holds 20 or more blocked accounts, OFAC recommends, but does not require, supplementing Part B of your ARBP with a spreadsheet along with your completed form.  Please send completed forms to OFACReport@treasury.gov.  Failure to submit a required report by September 30 constitutes a violation of 31 C.F.R. Part 501 (“Reporting, Procedures and Penalties Regulations”). 
 
For more information, click here to view OFAC’s Guidance on Filing the ARBP.

Links:

OFAC Notice

Annual Report of Blocked Property Form

Report Filing Guidance

Office of Financial Sanctions Implementation

 

Frozen Assets Reporting 2018

 

Every year the Treasury carries out a review to update its records to reflect any changes to frozen assets during the reporting period. 

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 OFSI by Friday 12 October 2018.

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 Friday 28 September 2018

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

And fuller information is in the attached notice…

Link:

HMT Notice

Remember the February 7th post about OFAC publishing TSRA licensing reports – the last one being July to September 2016? Well, first off, if you read the notice carefully, that release encompassed 4 quarterly reports (Oct-Dec 2105, Jan-Mar 2016, Apr-Jun 2016, Jul-Sep 2016). Secondly, not even a week later…

OFAC caught up – all the way! Five more reports, the latest being October through December of last year.

Happy reading!

Links:

OFAC Notice

TSRA Reports Page