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International Emergency Economic Powers Act (IEEPA) Economic Sanctions

King & Spalding

Ten-Year Statute of Limitations for Sanctions Violations Update

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As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

Foley Hoag LLP on

OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

Baker Botts L.L.P. on

In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control (“OFAC”) issue a notice changing U.S. sanctions – promulgating a new sanctions program or updating the designation of a...more

ArentFox Schiff

Investigations Newsletter: Former Congressman George Santos Pleads Guilty to Wire Fraud and Aggravated Identity Theft

ArentFox Schiff on

Former Congressman George Santos Pleads Guilty to Wire Fraud and Aggravated Identity Theft - On August 19, former US Representative George Santos pleaded guilty to wire fraud and aggravated identity theft. As part of the...more

Blank Rome LLP

OFAC Guidance on Extending the Statute of Limitations for Sanctions Violations Signals Aggressive Enforcement

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) last week issued guidance regarding the extension of the statute of limitations for sanctions violations. This guidance follows the enactment of...more

Sheppard Mullin Richter & Hampton LLP

SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement

On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten...more

Hogan Lovells

OFAC issues statute of limitations guidance for US sanctions violations and recordkeeping

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The US Department of the Treasury’s Office of Foreign Assets Control has released guidance following on Congress’ extension of the statute of limitations for violations of certain sanctions and related recordkeeping...more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

Seward & Kissel LLP on

The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

Katten Muchin Rosenman LLP

OFAC Announces Forthcoming Expanded Recordkeeping Rule

On July 22, 2024, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury issued a Guidance on Extension of Statute of Limitations (the "Guidance"). The Guidance calls attention to the recently...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

The Volkov Law Group on

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

Paul Hastings LLP on

Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

Fenwick & West LLP

OFAC Publishes Guidance on 10-Year Sanctions Violations Statute of Limitations

Fenwick & West LLP on

On July 22, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued guidance addressing the April 2024 extension of the statute of limitations for sanctions violations from five years to 10...more

Kelley Drye & Warren LLP

OFAC Publishes Guidance on Extension of Statute of Limitations and Recordkeeping Requirements

On July 22nd, 2024, OFAC published a guidance document regarding the 21st Century Peace through Strength Act’s extension of the statute of limitations for civil and criminal violations of the International Emergency Economic...more

Morgan Lewis

Commerce Issues First-Ever Ban on Information and Communications Technology and Services Transactions Under EO 13873

Morgan Lewis on

The Department of Commerce’s Bureau of Industry and Security (BIS) published a 13-page Final Determination on June 24, 2024 concerning cybersecurity and antivirus software supplied by a US subsidiary of a Russia-based...more

Locke Lord LLP

OFAC Doubles Statute of Limitations ‎for Sanctions Violations

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On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more

Braumiller Law Group, PLLC

Braumiller-Law-Group - June 2024 Newletter

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Skadden, Arps, Slate, Meagher & Flom LLP

Security Assistance Law Expanded the Reach of US Sanctions and Doubled the Statute of Limitations

On April 24, 2024, President Joe Biden signed the 21st Century Peace Through Strength Act (Act) into law. The Act, which is part of a broader law providing supplemental aid to Israel, Taiwan and Ukraine, contains several...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

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On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

Blank Rome LLP

President Biden Signs into Law Ten-Year Statute of Limitations for Sanctions Violations and Other National Security Measures

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President Biden last month signed into law H.R. 815 (“National Security Supplemental” or “NSS”). The NSS—a package of national security and foreign aid appropriations, including for efforts in Israel, Ukraine, and the...more

Hogan Lovells

Statute of limitations extended for violations of U.S. sanctions

Hogan Lovells on

Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.  Companies should be aware of the...more

Alston & Bird

National Security Act Ushers In Sweeping Changes to Sanctions Regulations

Alston & Bird on

On April 24, 2024, President Biden signed H.R. 815, otherwise known as the National Security Act of 2024. The bill provides emergency appropriations for Ukraine, Israel, Taiwan, humanitarian purposes in Gaza, and various...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - May 2024

On April 15, the U.S. Department of the Treasury published a proposed rule that would enhance certain Committee on Foreign Investment in the United States (CFIUS or the Committee) procedures and increase CFIUS penalty and...more

Kelley Drye & Warren LLP

Statute of Limitations for Sanctions Violations Increased to Ten Years

On April 24, 2024, the 21st Century Peace Through Strength Act became law. Although the Act contains many key national security policies, including aid for Ukraine and Israel, one provision that has been overlooked is a...more

Vinson & Elkins LLP

Not So Fast: Congress Doubles Statute of Limitations Period for U.S. Sanctions Violations in Foreign Aid Bill

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Following months of delays and intense debate in Congress, President Biden signed H.R. 815 into law on April 24, 2024, which made headlines for funding $95 billion in military aid to Ukraine, Israel, and Taiwan, along with...more

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