The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today released guidance addressing questions raised by recent legislation that extended the statute of limitations for violations of certain sanctions that the agency administers.
As explained in the guidance, OFAC may now commence an enforcement action for civil violations of International Emergency Economic Powers Act- or Trading with Enemy Act-based sanctions prohibitions within 10 years of the latest date of the violation if such date was after April 24, 2019.
To match the new statute of limitations period, OFAC anticipates publishing an interim final rule, with an opportunity to provide comment, extending from five years to 10 years the recordkeeping requirements codified at 31 C.F.R. § 501.601.
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