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ARTICLE · 07 AUGUST 2024

OFAC Issues Guidance Concerning Statute Of Limitations Extension

Foley Hoag LLP
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OFAC has released guidance regarding the extension of the statute of limitations, from 5 to 10 years, for violations of the International Emergency Economic Powers Act ("IEEPA") and the Trading with the Enemy Act ("TWEA").

United StatesIntellectual Property
Foley Hoag LLP
Foley Hoag LLP
Luciano Racco
Luciano Racco
Shrutih Tewarie
Shrutih Tewarie
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Key Takeaways:

  • OFAC has released guidance regarding the extension of the statute of limitations, from 5 to 10 years, for violations of the International Emergency Economic Powers Act ("IEEPA") and the Trading with the Enemy Act ("TWEA").
  • In the guidance, OFAC clarified that it can now bring an enforcement action for civil violations of IEEPA- or TWEA-based sanctions prohibitions within 10 years of the latest date of the violation if such date was after April 24, 2019. In addition, OFAC plans to extend its recordkeeping requirements under 31 C.F.R. § 501.601 from 5 years to 10 years.
  • Companies should prepare for these new changes by updating their compliance programs and record retention practices accordingly.

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