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 various U.S. sanctions-related measures. These sanctions measures extended the statute of limitations ("SOL") from five to ten years for civil and criminal violations of sanctions programs administered by the U.S. Treasury Department’s Office of Foreign Assets Control ("OFAC"). This change affects sanctions authorized under the International Emergency Economic Powers Act ("IEEPA") and the Trading with the Enemy Act ("TWEA"), doubling the time period during which companies can be held accountable for sanctions violations
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