What are the OFAC reporting deadlines?

Think 10 business days for each block, each rejected transaction, and each unblocking or transfer of blocked property (subject to the exceptions listed below), plus September 30 each year for blocked property you still hold. These cover the routine reports under 31 CFR part 501, and retained funds follow the same deadlines.

What the rule says:

• Initial blocking report: within 10 business days from the date property becomes blocked (31 CFR 501.603(b)(1)(i)).
• Rejected transaction report: within 10 business days of the rejected transaction, where the transaction is not blocked but processing it would still violate OFAC rules (31 CFR 501.604(a)(1), (c)). OFAC's guidance states the 10 business day rule for blocking and rejecting together (OFAC FAQ 5).
• Annual report: by September 30 each year, covering all blocked property held as of June 30 of that year, with each property valued as of June 30 (31 CFR 501.603(b)(2)).
• Unblocked or transferred property: within 10 business days from the date the property is unblocked or transferred, including under a valid order of a U.S. Government agency or U.S. court. No report is needed for authorized debits for normal service charges, authorized transfers between blocked accounts in a financial institution's own branches or offices, unblocking or transfer explicitly authorized by a license (unless the license requires a separate unblocking report), or unblocking because OFAC removed a person from the SDN List (31 CFR 501.603(b)(3)(i)).
• Retained funds: the same reporting requirements apply to any person retaining funds under 31 CFR 596.504(b) or releasing such funds (31 CFR 501.603(c)).

In practice:

• Start the clock at the blocking, rejection or release, and build that date into your alert-escalation workflow so the report is filed in time.
• File initial blocking and annual reports through the OFAC Reporting System, and rejected transaction reports through the same system (31 CFR 501.603(d)(1), 501.604(d)). Unblocking or transfer reports may go by email to [email protected], with the section number in the subject line, or through the system (31 CFR 501.603(d)(2)). Alternative filing is available only on a showing of unique and extraordinary circumstances, and requests are presumed denied.
• Keep a copy of each report under 31 CFR 501.603 (31 CFR 501.603(d)(1)). Section 501.604 has no copy rule, but OFAC says to retain related records under its recordkeeping requirements (OFAC FAQ 5).

Timing: the 10 day periods are counted in business days.

Sources

1. 31 CFR § 501.603(a)(1), (b)(1)(i)-(ii), (c), (d)(1): https://www.law.cornell.edu/cfr/text/31/501.603
2. 31 CFR § 501.604(a)(1), (a)(3), (b), (c), (d); OFAC FAQ 5: https://www.law.cornell.edu/cfr/text/31/501.604
3. 31 CFR 501.603 (eCFR): https://www.ecfr.gov/current/title-31/section-501.603
4. 31 CFR 501.604 (eCFR): https://www.ecfr.gov/current/title-31/section-501.604

This answer is general information, not legal advice. Forteris is not a law firm.