Treasury Implements REPO for Ukrainians Act Reporting Requirement

WASHINGTON — Today, as part of implementing the historic Rebuilding Economic Prosperity and Opportunity for Ukrainians Act (the “REPO for Ukrainians Act”), 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 assets. Pursuant to section 104(a) of the REPO for Ukrainians Act, all financial institutions at which Russian sovereign assets are located, and that know or should know of such assets, must 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.As described in more detail in the full instructions and in the REPO for Ukrainians Act Report Form, financial institutions should not re-report information on Russian sovereign assets that was previously reported to OFAC.