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ARTICLE · 16 SEPTEMBER 2024

OFAC Extends Recordkeeping Requirements From 5 To 10 Years Through Interim Final Rule

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On September 11, 2024, the Department of the Treasury's Office of Foreign Assets Control (OFAC) announced that it is seeking comments on a new interim final rule amending OFAC's Reporting, Procedures and Penalties...

IsraelInternational Law
David (Dj) Wolff
David (Dj) Wolff
Anand Sithian
Anand Sithian
Jeremy Iloulian
Jeremy Iloulian
Edward Goetz
Edward Goetz

On September 11, 2024, the Department of the Treasury's Office of Foreign Assets Control (OFAC) announced that it is seeking comments on a new interim final rule amending OFAC's Reporting, Procedures and Penalties Regulations to extend recordkeeping requirements from five to ten years. While OFAC is seeking comments within 30 days, the interim final rule is effective as of September 11, 2024.

This change is driven by the 21st Century Peace through Strength Act, signed into law by the President on April 24, 2024, which extended the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) from five to ten years. As a result, the U.S. government may now commence an enforcement action for civil or criminal violations of IEEPA- or TWEA-based sanctions prohibitions within 10 years of the latest date of the violation. Pursuant to subsequently issued guidance from OFAC, the

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