OFAC Issues New Russian Asset Reporting Rules Under REPO for Ukrainians Act
The Office of Foreign Assets Control this week published new reporting requirements for banks and other financial institutions under a law that allows the U.S. to use certain frozen Russian assets to help support and rebuild Ukraine.
As part of the Rebuilding Economic Prosperity and Opportunity (REPO) for Ukrainians Act, which was signed into law in April (see 2405210064 and 2404240043), all financial institutions holding Russian sovereign assets, or that “know or should know of such assets,” must report those assets to OFAC by Aug. 2 or within 10 days “of the detection of such assets,” the agency said. Financial institutions must use OFAC’s new REPO Report Form to disclose those assets.
A “reporting instructions” document issued by OFAC said those reports must include:
- the name and address of the person in control of the property
- the date the property came into the control of that person
- the person that owns the account or property
- a description of the property and its location, including any relevant account types, account numbers, reference numbers, dates, or other information needed to identify the property
- the actual or estimated value of the property in U.S. dollars. Foreign currencies must be reported in U.S. dollars with the foreign currency amount and notional exchange rate in the narrative
- a copy of the most recent relevant account statement or other documentation to support that estimated value.
The agency said it defines Russian sovereign assets as funds and other property of the Central Bank of Russia, the Russian National Wealth Fund, the Russian Ministry of Finance, or “any other funds or other property that are owned by the Government of the Russian Federation, including by any subdivision, agency, or instrumentality of that government.” OFAC said institutions shouldn’t report information on those Russian sovereign assets if they were already reported to OFAC.