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ARTICLE · 08 MAY 2024

US Congress Extends Statute Of Limitations For Sanctions And Export Controls

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On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the "Act").1 While much of the focus centered on the foreign aid package for Israel...

GlobalInternational Law
Tamer A. Soliman
Tamer A. Soliman
Adam S. Hickey
Adam S. Hickey
Timothy Keeler
Timothy Keeler
Gretel Echarte Morales
Gretel Echarte Morales
Emily King
Emily King
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On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the "Act").1 While much of the focus centered on the foreign aid package for Israel, Ukraine, and the Indo-Pacific, the bill contains a highly consequential provision that extends the statute of limitations under the International Emergency Economic Powers Act ("IEEPA") and the Trading with the Enemy Act ("TWEA"). IEEPA is the statutory authority underpinning the US sanctions regime and grants authority to the US Department of Treasury's Office of Foreign Assets Control ("OFAC") and the US Department of Commerce's Bureau of Industry and Security ("BIS") to administer and enforce US sanctions programs, while TWEA grants authority for the OFAC Cuba sanctions program.

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