News & Analysis as of

Recordkeeping Requirements Statute of Limitations

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

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

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

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

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

Proskauer - Employee Benefits & Executive...

Massachusetts District Court Grants Motion to Dismiss 401(k) Fiduciary Breach and Prohibited Transaction Claims

A federal district court in Massachusetts dismissed ERISA fiduciary breach and prohibited transaction claims against 401(k) plan fiduciaries, ruling that the prohibited transaction claims were time-barred and the fiduciary...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Revisiting Volks - Is OSHA Buying Itself More Time to Issue More Citations?

Recordkeeping under the Occupational Safety and Health (OSH) Act is often top of mind for workplace safety professionals. Under the OSH Act, employers must record injuries and illnesses resulting in medical treatment beyond...more

Lowenstein Sandler LLP

SBA Announces: “SBA may begin a review of any PPP loan of any size at any time in SBA’s discretion” & DOJ Announces Multiple...

Lowenstein Sandler LLP on

Between May 20 and May 22, SBA announced three new Interim Final Rules and the U.S. Department of Justice (DOJ) announced three new fraud prosecutions stemming from PPP loans. Those prosecutions reflect that the DOJ does not...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Governor Murphy Proposes Numerous Changes to the New Jersey Law Against Discrimination

On February 18, 2020, Governor Phil Murphy proposed a host of legislative changes to the New Jersey Law Against Discrimination (NJLAD) (N.J.S.A. 10:5-1, et seq.). According to the governor, the changes aim “to clarify legal...more

Holland & Hart - Health Law Blog

Record Retention and Destruction for Wyoming Healthcare Entities

Medical Record Retention Guidelines for Wyoming Clients frequently ask us how long they should retain medical records and related business records. The answer depends on various factors, including the type of record,...more

Holland & Hart - Health Law Blog

Record Retention and Destruction for Utah Healthcare Entities

Medical Record Retention Guidelines for Utah Clients frequently ask us how long they should retain medical records and related business records. The answer depends on various factors, including the type of record, applicable...more

Holland & Hart - Health Law Blog

Record Retention and Destruction for Idaho Healthcare Entities

Medical Record Retention Guidelines for Idaho Clients frequently ask us how long they should retain medical records and related business records. The answer depends on various factors, including the type of record,...more

Fisher Phillips

What’s Next Now that OSHA Rescinded Part of the Electronic Recordkeeping Requirements?

Fisher Phillips on

As we reported earlier yesterday, OSHA released its Final Rule eliminating the responsibility of certain employers to electronically submit to OSHA data from its Form 300 Workplace Injury and Illness Log and the 300A forms...more

Seyfarth Shaw LLP

California Enacts New Record-Keeping Mandates In Response To Changing Federal Program

Seyfarth Shaw LLP on

Seyfarth Synopsis: Last week, Governor Brown signed into law Assembly Bill No. 2334, Occupational Injuries and Illness, Employer Reporting Requirements, and Electronic Submission....more

Jackson Lewis P.C.

California Legislature Says Recordkeeping Violations Not Subject To Six-Month Statute Of Limitations

Jackson Lewis P.C. on

Beginning in 2019, employers in California will now be on the hook for recordkeeping violations well beyond the six-month statute of limitations. Bill Number AB 2334 (Occupational injuries and illnesses: employer reporting...more

Fisher Phillips

California Enacts New Law to Respond to Trump Administration OSHA Changes

Fisher Phillips on

On September 19, Governor Brown signed AB 2334 (Thurmond) to make various workplace safety and health changes to California law, largely in response to recent activity by the Trump Administration. Among other things, AB 2334...more

Fisher Phillips

And Now The Bad News: Avalanche of California Bills Continues to Advance

Fisher Phillips on

As we discussed in our last blog post, California employers received some rare good news in recent days.  Bills to expand California’s paid sick leave requirement and to require employers to accommodate medical marijuana use...more

Fisher Phillips

Sexual Harassment Dominates California Legislation in 2018

Fisher Phillips on

As we discussed back in January, sexual harassment appears to be the hot topic for the California State Legislature’s 2018 session. This is certainly not a surprise, as issues related to sexual harassment and the #MeToo...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Lawlessness Quashed, Part II: President and Congress Stop OSHA’s Attempt to Avoid the Volks Decision

On Monday, April 3, 2017, President Trump signed a Congressional Review Act resolution, passed by the House on March 1 and by the Senate on March 22, that disapproves of the Occupational Safety and Health Administration’s...more

Miller Canfield

OSHA’s Attempt to Expand Citation Statute of Limitations Thwarted by Congressional Review Act Senate Vote

Miller Canfield on

On March 22, 2017, the Senate, by a vote of 50-48, passed a House of Representatives’ resolution which overturned the OSHA Rule seeking to expand the statute of limitations period for citations it issues to employers. ...more

Amundsen Davis LLC

Senate Approves Measure to Kill OSHA Statute of Limitations Change for Recordkeeping Violations

Amundsen Davis LLC on

On March 22, 2017, the U.S. Senate passed a measure to revoke OSHA’s modification to the six-month statute of limitations for recordkeeping violations. Under the Obama Administration, OSHA issued a new rule to extend the...more

Jackson Lewis P.C.

House of Representatives Votes to Block OSHA Recordkeeping Rule

Jackson Lewis P.C. on

The House of Representatives has voted to block a new Occupational Safety and Health Administration recordkeeping rule implemented in the last weeks of the Obama Administration. “Clarification of Employer’s Continuing...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Quashing Lawlessness: Congress Votes on OSHA’s Attempt to Avoid the Volks Decision

An appellate court one level below the Supreme Court of the United States, and highly respected in the field of administrative law, recently held that the Occupational Safety and Health Administration’s (OSHA) interpretation...more

Pillsbury - Gravel2Gavel Construction & Real...

Battle Brewing Over “Continuing Violations” Theory?

OSHA has just published a Final Rule restating its interpretation of the “continuing violations” theory. There are now two Circuit Court of Appeals rulings that disagree with this interpretation: AKM LLC dba Volks Contractors...more

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