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
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
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
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
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory outlining the risks involved with facilitating ransom payments to malicious actors conducting...more