Sanctions Update: OFAC Extends Recordkeeping Requirements To 10 Years And Amends Reporting Regulations

In recent weeks, the US Department of the Treasury's Office of Foreign Assets Control ("OFAC") has introduced an interim and a final rule amending its regulations with important implications for sanctions compliance programs. First, OFAC's general recordkeeping requirements under 31 C.F.R. § 501.601, as well as other provisions, will be extended from 5 years to 10 years, effective March 12, 2025. Second, OFAC finalized additional amendments to its Reporting, Procedures and Penalties Regulations, adding four exceptions to the reporting requirements for blocked property that is unblocked or transferred, as well as clarifying certain other changes.

Extension of Recordkeeping Requirements Aligns With Statutory Amendments to National Security Statutes