News & Analysis as of

Interim Final Rules (IFR) Office of Foreign Assets Control (OFAC)

Adams and Reese LLP

International Compliance Digest - September 2024

Adams and Reese LLP on

New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

Husch Blackwell LLP

OFAC Issues Guidance Extending Statute of Limitations to 10 Years

Husch Blackwell LLP on

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

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

BakerHostetler on

In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Davis Wright Tremaine LLP

Deadline Approaching for Filing 2024 OFAC Annual Report of Blocked Property

The annual September 30 deadline for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) is fast approaching. Under federal regulations, "all U.S....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

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

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

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - June 2024

Lowenstein Sandler LLP on

On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more

Akin Gump Strauss Hauer & Feld LLP

OFAC Revamps Reporting Requirements

Key Points - On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to...more

Bracewell LLP

OFAC Expands Recordkeeping Requirements, Mandates Electronic Filings

Bracewell LLP on

Last week, the Office of Foreign Assets Control (OFAC) announced an interim final rule which amends the recordkeeping and reporting requirements relating to the various economic sanctions programs it enforces. Notably, the...more

Morgan Lewis

Sweeping US Export Controls on Semiconductor, Supercomputer Manufacturing in China Raise Compliance Questions

Morgan Lewis on

The US Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) on October 7, 2022, imposing additional export controls on certain advanced computing and semiconductor manufacturing...more

Foley Hoag LLP

Biden Administration Focus on Cybercrime Continues with Israeli Companies Added to Entity List, New Export Controls, and...

Foley Hoag LLP on

On November 3, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added two Israeli entities to the Entity List due to malicious cyber activities. In its press release, BIS stated that the...more

Bass, Berry & Sims PLC

Update on U.S. Sanctions: New Requirements, Continuing Enforcement

• OFAC proposes new reporting requirement for rejected transactions • Agency issues guidance on dealing with Iran • Additional parties designated under Magnitsky sanctions program • Careful diligence of...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Issues Interim Final Rule Extending Reporting Requirements for Rejected Transactions to Companies Outside the Financial...

• On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued and put into effect an Interim Final Rule (Interim Rule) that requires all U.S. persons and persons subject to U.S....more

Holland & Hart LLP

OFAC Expands Sanctions-Related Rejected Transaction Reporting Requirements

Holland & Hart LLP on

On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule amending the Reporting, Procedures and Penalties Regulations, 31 CFR part 501 (“RPPR”). This...more

Ballard Spahr LLP

OFAC’s Revised Reporting Rules Create New Compliance Requirements for All U.S. Persons

Ballard Spahr LLP on

“Rejected Transactions” Reporting: Additional Compliance Obligations for Financial Institutions; New Compliance Obligations Businesses, Nonprofits, Inividuals, and Foreign Entities Owned or Controlled by U.S. Persons - The...more

Jones Day

OFAC Dramatically Expands Reporting Obligations

Jones Day on

Ambiguous, undefined terms create uncertainty and confusion, including whether owned or controlled subsidiaries of U.S. companies outside the United States are subject to this reporting requirement. On June 21, the...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Spanish

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

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