Russia-related Designations; Issuance of Russia-related General Licenses and Amended FAQ; Publication of BPI Regulatory Amendment; Reminder to File the 2024 Annual Report of Blocked Property

The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued the new, Russia-related General License 109, "Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on September 13, 2024" and Russia-related General License 25F, "Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications." OFAC also published an updated, Russia-related Frequently Asked Question (FAQ 1040). Additionally, OFAC published a final rule on Updating Provisions Related to Blocking and Other Actions Related to Specific Property or Interests in Property. A reminder to holders of blocked property: 31 C.F.R. § 501.603 of the Reporting, Procedures and Penalties Regulations (RPPR) requires holders of blocked property to provide the Office of Foreign Assets Control (OFAC) with a comprehensive list of all blocked property held as of June 30 of the current year by September 30, referred to as an Annual Report of Blocked Property (ARBP). Persons that did not hold blocked property as of June 30 do not need to file an ARBP. Please note that the term blocked property only applies to property that is blocked pursuant to OFAC regulations. Property that was unblocked by an OFAC general or specific license or was previously blocked pursuant to a sanctions program that was terminated on or before June 30, 2024, is not considered blocked property, and should not be reported in the ARBP. Similarly, a restricted account of a person ordinarily resident in Iran is not blocked and should not be reported to OFAC in the ARBP, unless there is an interest in the account of a person whose property and interests in property are blocked pursuant to an applicable sanctions authority. Persons filing the 2024 ARBP are required to utilize spreadsheet form TD-F 90-22.50. Completed forms should be filed through the OFAC Reporting System (ORS). Failure to submit a required ARBP by September 30 constitutes a violation of the RPPR. Lastly, OFAC has made the following changes to its SDN List.