31 CFR § 501.603 - Reports on blocked property.

Date issued: Mar. 01 2024

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TURBOFAC Commentary (1083 words)

Notes:

This provision was amended substantially in June, 2019, to radically expand the scope of the reporting obligations. Individual subsections are discussed below. Refer to Guidance on Filing the Annual Report of Blocked Property (2019).

*501.603(a)(1):

1.1) Provision amended in 2019 to clarify that persons "releasing property from blocked status" are subject to reporting requirements. This applies only “when specifically required by OFAC, such as when [reports] are made a condition of a general or specific license.”

Concurrently, the language "who have or have had in their possession or control any property blocked pursuant to this chapter" was added. It is possible that the "or have had" is merely a reference to persons that were holding blocked property that was released it from blocked status in accordance with the law, but it is also possible that OFAC is saying that persons that...