OFAC Blocked Property and Rejected Transaction Report Deadline Calculator
Pick what happened and when, and get the date your OFAC report is due.
Your Report Date
How we count: Monday to Friday, skipping the federal holidays listed in 5 U.S.C. §6103(a) when they fall on a weekday. The day of the event is day 0. We do not skip the Friday or Monday on which a weekend holiday is observed, so the date shown is never later than a count that skips that observed day too. 31 CFR Part 501 does not define “business day”.
When Each OFAC Report Is Due
An initial OFAC blocked property report must be filed within 10 business days from the date the property becomes blocked. Under 31 CFR §501.603(b)(1)(i), this 10-business-day deadline applies to any U.S. person or person subject to U.S. jurisdiction holding blocked property. Four distinct filing requirements apply across different transaction events:
- Initial blocking report: due within 10 business days from the date property becomes blocked under 31 CFR §501.603(b)(1)(i).
- Rejected transaction report: due within 10 business days of the rejected transaction under 31 CFR §501.604(c).
- Report of blocked property unblocked or transferred: due within 10 business days from the date property is unblocked or transferred under 31 CFR §501.603(b)(3)(i), with specific exceptions set out in paragraphs (A) through (D).
- Annual report of blocked property: due every September 30 for all blocked property held as of June 30 of that year under 31 CFR §501.603(b)(2)(i).
Under 31 CFR §501.603(a), any U.S. person, including a financial institution holding, unblocking, or transferring blocked property, must report. For the Cuban Assets Control Regulations (Part 515), this obligation extends to any person subject to U.S. jurisdiction. Primary reporting responsibility rests with the holder, though an attorney or agent may submit filings on their behalf.
For an event occurring on Monday, November 2, 2026, the calculator skips Veterans Day on Wednesday, November 11. The initial blocking report is due by Tuesday, November 17, 2026. If that property remains held on June 30, 2027, it must also appear on the annual report of blocked property filed by September 30, 2027.
How the Calculator Counts Business Days
The calculator counts business days from Monday to Friday, treating the date of the event as day 0. Part 501 of Title 31 does not define "business day" directly in the regulation text.
The calculator skips the 11 legal public holidays in 5 U.S.C. §6103(a) when they fall on a weekday:
- New Year's Day
- Birthday of Martin Luther King, Jr.
- Washington's Birthday
- Memorial Day
- Juneteenth National Independence Day
- Independence Day
- Labor Day
- Columbus Day
- Veterans Day
- Thanksgiving Day
- Christmas Day
When a federal holiday falls on a weekend, the calculator does not skip the observed Friday or Monday. That keeps the date shown from running later than a count that skips the observed day too. In our internal analysis at Cuban Insights, we encoded the 10-business-day rule and the 11 holidays in 5 U.S.C. §6103(a). We then checked the calculator against fixed dates, including November 2, December 18 and June 26, 2026.
The holiday rules produce distinct deadlines across the calendar year:
- A transaction rejected on Friday, December 18, 2026 skips Christmas Day (Friday, December 25) and New Year's Day (Friday, January 1, 2027), making the rejected transaction report due by Tuesday, January 5, 2027.
- Independence Day falls on Saturday, July 4, 2026. The calculator does not skip Friday, July 3, 2026, so an event on Friday, June 26, 2026 results in a deadline of Friday, July 10, 2026.
You can check whether a party or vessel is on the SDN list with the OFAC Cuba sanctions checker.
How to Use the Calculator
Select the transaction type using the menu labelled "What happened" to configure the counting logic. The menu provides four choices:
- "I blocked property (initial blocking report)"
- "I rejected a transaction (rejected transaction report)"
- "Blocked property was unblocked or transferred"
- "Annual report of blocked property"
Enter the date of the event in the input field labelled "Date it happened". When selecting the annual report, this label changes to "A date the property is blocked". The date field defaults to today's date so a result generates on first load.
The result view updates immediately whenever you change either input field. The interface displays "Due by" with the full calendar date, the governing legal citation, and the 10 counted business days enumerated from Day 1 to Day 10. The output names any skipped federal holidays, notes the September 30 annual filing requirement for blocked assets, and provides a direct link to the OFAC Reporting System.
The calculator runs entirely inside your browser, and no entered dates or selections are transmitted over a network. You can save your record using the "Copy as text", "Add to calendar (.ics)", or "Print / save as PDF" buttons. The printed output includes an "OFAC Report Deadline" title and a dedicated "Matter / reference" line for filing. For background on OFAC itself, read What Is OFAC?.
What the Initial Report Must Include
Under 31 CFR §501.603(b)(1)(ii), initial reports on blocked property must include specific identifying details. Required data includes the name, address, and contact information of the person holding the property. Filers must also provide a description of the property, its location, and any relevant reference or account numbers.
The filing must identify the associated sanctions target, the exact date the property was blocked, and its actual or estimated value in U.S. dollars. Under OFAC FAQ 402, blocked property or interests in property that come into the possession or control of a U.S. person must be blocked and reported to OFAC. According to the OFAC Revised Guidance issued on August 13, 2014, property subject to blocking includes any property or interest in property, whether tangible or intangible, including present, future, or contingent interests.
All initial blocking reports must be submitted electronically through the OFAC Reporting System under 31 CFR §501.603. Rejected transaction filings follow the same submission path under 31 CFR §501.604(d). For complex ownership structures, filers can verify aggregate corporate ownership thresholds with the OFAC 50 percent rule calculator.
The September 30 Annual Report
The annual report of blocked property covers all blocked property held as of June 30 of the current calendar year. Under 31 CFR §501.603(b)(2)(i), this filing must be submitted annually by September 30. Each annual submission must specify the date each item of property was originally blocked and its recorded valuation as of June 30.
The timing of the initial blocking determines which annual cycle captures the asset:
- Property blocked on June 30, 2026 must be included in the annual report filed by September 30, 2026.
- Property blocked on July 1, 2026 does not appear in the 2026 annual report. It first appears in the report due September 30, 2027 if it remains blocked on June 30, 2027.
Entities handling authorized transactions can evaluate specific permissions using the OFAC Cuba general licenses guide.
Records to Keep
Under 31 CFR §501.601, transaction records must be available for at least 10 years after the transaction.
Holders must retain records concerning blocked property for the entire period the property remains blocked. Once the asset is unblocked, parties must retain those property records for at least 10 years after the date of unblocking.
Exported records from this calculator provide planning documentation for internal files. Use the "Print / save as PDF" button to save or print your counted deadlines.
Frequently Asked Questions
What is OFAC blocked property?
Property blocked under OFAC regulations is broadly defined to include any property or interest in property, tangible or intangible. Under the OFAC Revised Guidance issued on August 13, 2014, this scope covers present, future, and contingent interests. When such property comes into the possession or control of a U.S. person, it must be blocked and reported to OFAC under OFAC FAQ 402.
How many days do I have to report blocked property to OFAC?
You have 10 business days to report blocked property to OFAC. Under 31 CFR §501.603(b)(1)(i), the holder must file an initial report on the blocked property within 10 business days from the date the property becomes blocked.
Do I have to report a rejected transaction to OFAC?
Yes, you must report a rejected transaction to OFAC. Under 31 CFR §501.604(a) and 31 CFR §501.604(c), any U.S. person or person subject to U.S. jurisdiction that rejects a transaction whose processing would violate sanctions must submit a report within 10 business days. Covered transactions include wire transfers, trade finance, securities, checks, foreign exchange, and transactions related to goods or services.
When is the annual report of blocked property due?
The annual report of blocked property is due by September 30 of each year. Under 31 CFR §501.603(b)(2)(i), this report covers all blocked property held by the reporting party as of June 30 of that year.
Where do I file an OFAC report?
You file initial blocking and rejected transaction reports electronically through the OFAC Reporting System. The requirement to file reports through this electronic system is established under 31 CFR §501.603 and 31 CFR §501.604(d).
Does the deadline count weekends and holidays?
No, the 10-day reporting deadline counts business days rather than calendar days. The calculator counts Monday through Friday and skips the 11 federal holidays designated in 5 U.S.C. §6103(a) that fall on a weekday. When a holiday falls on a weekend, the calculator does not skip the observed Friday or Monday, so its date is never later than a count that skips that day too.
File through the OFAC Reporting System on or before the date the calculator shows.
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