Yesterday, the United States Department of the Treasury Office of Foreign Assets Control (OFAC) released its annual report on Assets in the United States of Terrorist Countries and International Terrorism Program Designees.

According to OFAC, as of December 31, 2010, blocked assets of those parties who had been designated as OFAC Specially Designated Nationals (SDNs) pursuant to one of the terrorism sanctions regulations and those Foreign Terrorist Organizations (FTO) which are designated pursuant to the Anti Terrorism Act of 1996 totaled $22,009,973.

The total assets for state sponsors of terror equaled more than $424 million in assets relating to four nations purported to be state sponsors of terrorism.. Of that amount, $309 million in assets are blocked pursuant to economic sanctions imposed by the United States and administered by OFAC. The remaining balance of $115 million in assets represents non-blocked assets of individuals and entities located in Iran and Syria.

The sources of information that OFAC uses in this report vary depending on the nature of the sanctions target. With respect to terrorists and terrorist organizations, OFAC relies solely on information that U.S. persons are obligated to report to OFAC with respect to blocked assets. With respect to state sponsors of terrorism, OFAC relies primarily on reports of blocked property when applicable, but also has obtained additional information deemed appropriate for inclusion in the report.

It should be noted that the blocked funds reported upon in this report to Congress are not all wholly owned by what OFAC refers to as terrorists or terrorist states. Many of the assets are blocked due to a partial interest of a blocked person or a blocked country. If you have an interest in some blocked property then there is a formal process for unblocking such property. This process involves submitting an application for an unblocking license from OFAC. Although this process does actually utilize a form application, it is not streamlined when it comes to processing time. Waiting to obtain your license to unblock property you have an interest in can take a very long time.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.

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