---
title: "List blocked property for an OFAC initial report"
url: "https://ailawframework.com/practice/not-for-profit-charities-and-associations/build-an-overseas-activities-due-diligence-file/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A35-T1-R14-US"
practice_area: "Not-for-Profit, Charities & Associations"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# List blocked property for an OFAC initial report

> 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…

Canonical page: https://ailawframework.com/practice/not-for-profit-charities-and-associations/build-an-overseas-activities-due-diligence-file/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Not-for-Profit, Charities & Associations](https://ailawframework.com/practice/not-for-profit-charities-and-associations.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| 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 | United States |
| Applies to | [Build an overseas-activities due-diligence file](https://ailawframework.com/practice/not-for-profit-charities-and-associations/build-an-overseas-activities-due-diligence-file.md) |

## Checking plan

- What the AI does: 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.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Part 515 and the definition of a U.S. person in each sanctions part were not opened. Do not decide who is a U.S. person.
- The 50 Percent Rule guidance named in FAQ 9 was not opened. Do not treat an entity as blocked because of an owner's stake.
- A loan, a credit-card receivable, or other property with a negative balance is reported as zero, with the amount owed in a narrative. Do not report the debt balance as the blocked amount.

## Sources

- [31 CFR § 501.603, reports of blocked property](https://www.law.cornell.edu/cfr/text/31/501.603) (checked 2026-10-22)
- [OFAC FAQ 9, blocked property](https://ofac.treasury.gov/faqs/9) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [External Conduct Standards file for a charity operating outside Australia](https://ailawframework.com/precedents/not-for-profit-charities-and-associations/external-conduct-standards-file.md) | Checklist | Yellow | File for the four ACNC External Conduct Standards, and for whether the charity operates outside Australia at all. It records the steps the charity has taken. It does not say the standards are met. |

Signed-in accounts can read the full text of each one.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*