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ARTICLE · 20 SEPTEMBER 2024

OFAC Extends Recordkeeping Requirement To 10 Years

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On September 11, 2024, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (the IFR), effective March 12, 2025, that extends OFAC's...

United StatesInternational Law
Peter Jeydel
Peter Jeydel
David M. Stetson
David M. Stetson
Edward Krauland
Edward Krauland
Jack Hayes
Jack Hayes
Brian J. Fleming
Brian J. Fleming
Jonathan Eaton
Jonathan Eaton

On September 11, 2024, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (the IFR), effective March 12, 2025, that extends OFAC's general recordkeeping requirement from five years to 10 years. The IFR aligns OFAC's recordkeeping requirement with the recent extension of the statute of limitations (SOL) period for civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA), which took effect on April 24, 2024, when President Biden signed into law HR 815, the National Security Supplemental (discussed here).

OFAC previewed the change in the IFR on July 22, 2024, by issuing guidance on the aforementioned SOL extension. The IFR is consistent with what OFAC had previewed, but is not effective for approximately six months. Any parties with comments on the IFR must submit them to OFAC by October 15, 2024.

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