On July 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a new reporting requirement for financial institutions holding Russian sovereign asset as part of implementing the historic Rebuilding Economic Prosperity and Opportunity for Ukrainians Act (the “REPO for Ukrainians Act”). The new reporting requirement mandates all financial institutions at which Russian sovereign assets are located, and that know or should know of such assets, to provide notice of such assets to OFAC no later than August 2, 2024 or within 10 days of the detection of such assets, and can do so via OFAC’s new form.

The full instructions of the reporting requirements are detailed in the REPO for Ukrainians Act Report Form and will be available in the Federal Register. The OFAC clarified that financial institutions should not re-report information on Russian sovereign assets that was previously reported to OFAC.

Read the Treasury’s press release here.

The REPO Report Form can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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