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Office of Foreign Assets Control (OFAC) International Emergency Economic Powers Act (IEEPA)

Husch Blackwell LLP

OFAC Issues Guidance Extending Statute of Limitations to 10 Years

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On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50, div. D. Part of the Act included a provision extending the statute of limitations for civil and criminal...more

King & Spalding

Ten-Year Statute of Limitations for Sanctions Violations Update

King & Spalding on

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

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

White & Case LLP

Sanctions move up the agenda for lenders and borrowers

White & Case LLP on

Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more

Foley Hoag LLP

OFAC Issues Guidance Concerning Statute of Limitations Extension

Foley Hoag LLP on

On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50 (the “Act”). By doing so, the statute of limitations (“SoL”) for violations, both criminal and civil, of IEEPA...more

Blank Rome LLP

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

Blank Rome LLP on

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

Venable LLP

Impact of Loper Bright on International Trade Issues

Venable LLP on

Recently, Venable's Government Division offered its general thoughts on the fallout from the Supreme Court's reversal of the long standing Chevron deference principle. Here, the International Trade and Logistics Group offers...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

Hogan Lovells on

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

Holland & Hart LLP

Guidance on Extension of Statute of Limitations for Civil and Criminal Violations of Sanctions Authorities

Holland & Hart LLP on

On July 22, 2024, the Office of Foreign Assets Control (“OFAC”) published guidance regarding recent legislation extending the statute of limitations for civil and criminal violations of the International Emergency Economic...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

Davis Wright Tremaine LLP

OFAC Provides Guidance on Extended Statute of Limitations

As we previously reported, effective April 24, 2024, the statute of limitations for most civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) or the Trading with the Enemy Act (TWEA) has...more

Holland & Knight LLP

Commerce Department: Final Determination of Russia-Backed Cybersecurity, Antivirus Software

Holland & Knight LLP on

The U.S. Department of Commerce's Office of Information and Communications Technology and Services (OICTS) within the Bureau of Industry and Security (BIS) issued a Final Determination on June 20, 2024, pursuant to Executive...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

Snell & Wilmer

United States Government Doubles Statute of Limitations for Sanctions Violations

Snell & Wilmer on

Shrouded within the supplemental emergency appropriations bill for Israel, Ukraine, and Taiwan, the 21st Century Peace through Strength Act passed by Congress and signed into law significantly increases the statute of...more

Locke Lord LLP

OFAC Doubles Statute of Limitations ‎for Sanctions Violations

Locke Lord LLP on

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

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