List blocked property for an OFAC initial report
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- From the file, list the holder, a description of the property and its location, the date the file says the property was blocked, the value the file states, and any sanctions target and legal authority the file already names. Do not file a report, and do not decide that a person is blocked.
- What the lawyer must review
- You decide whether property is blocked, and you file any report. 31 CFR § 501.603(a) requires a U.S. person holding, unblocking, or transferring property blocked pursuant to chapter V to submit the reports in that section. An attorney or agent may file, but primary responsibility rests with the holder, transferor, or releaser, or the person exercising control over property outside the United States. For trust assets it rests with the trustee. For real property it rests with a U.S. co-owner, legal representative, agent, or property manager in the United States. Another person's report excuses the filing only on actual knowledge of that report. An initial report is due within 10 business days from the date the property becomes blocked, and it includes the holder's name and address and a contact, a description of the associated transaction and the persons participating in it, the sanctions target and that target's interest, a description and location of the property, the date it was blocked, the actual or estimated value in U.S. dollars, any action taken with respect to the property, the legal authority, and copies of related payment or transfer documents. The term SDN is not a legal authority. A report of all blocked property held as of 30 June is filed annually by 30 September. A report that property was unblocked or transferred is due within 10 business days, except for an authorised debit for a normal service charge, an authorised transfer between blocked accounts in the same institution's branches or offices, an unblocking or transfer that a specific or general license explicitly authorises unless the license requires a separate report, and an unblocking because OFAC removed the person from the SDN List. OFAC's FAQ 9 describes blocking as freezing, not seizure. Title stays with the blocked person, and the property may not be transferred or otherwise dealt in without OFAC authorisation. The 50 Percent Rule page named in that FAQ was not opened.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Supporting preparation only. Potential support includes organising research leads. Confirm the tool’s capability and permitted scope. The tool writes nothing into the document. Substantive advice, judgement and any restricted content remain with the responsible human. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Open each relied-on authority independently. Confirm its existence, current status, proposition and any quotation or pinpoint reference.
- Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
- Calculate operative dates independently from the current rule and actual triggering event. Check exceptions and record the verified deadline.
- Check the current court or regulator requirements, prescribed form and attachments for the intended document and filing.
- Review operative clauses in the complete document, including definitions, cross-references, schedules and inconsistencies with the instructions.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.