News & Analysis as of

International Emergency Economic Powers Act (IEEPA) TWEA Statute of Limitations

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

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

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

The Volkov Law Group on

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

Kelley Drye & Warren LLP

OFAC Publishes Guidance on Extension of Statute of Limitations and Recordkeeping Requirements

On July 22nd, 2024, OFAC published a guidance document regarding the 21st Century Peace through Strength Act’s extension of the statute of limitations for civil and criminal violations of the International Emergency Economic...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

Braumiller Law Group, PLLC

Braumiller-Law-Group - June 2024 Newletter

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

Skadden, Arps, Slate, Meagher & Flom LLP

Security Assistance Law Expanded the Reach of US Sanctions and Doubled the Statute of Limitations

On April 24, 2024, President Joe Biden signed the 21st Century Peace Through Strength Act (Act) into law. The Act, which is part of a broader law providing supplemental aid to Israel, Taiwan and Ukraine, contains several...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

The Volkov Law Group on

On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

Blank Rome LLP

President Biden Signs into Law Ten-Year Statute of Limitations for Sanctions Violations and Other National Security Measures

Blank Rome LLP on

President Biden last month signed into law H.R. 815 (“National Security Supplemental” or “NSS”). The NSS—a package of national security and foreign aid appropriations, including for efforts in Israel, Ukraine, and the...more

Orrick, Herrington & Sutcliffe LLP

New U.S. Legislation Extends Sanctions Statute of Limitations and Authorizes New Sanctions: What Companies Need to Know

The 21st Century Peace Through Strength Act became law recently as part of H.R. 815, which also provided aid to Ukraine, Israel and Taiwan. The law contains important sanctions measures that: Extend the statute of...more

Akin Gump Strauss Hauer & Feld LLP

Congress Extends Statute of Limitations for Sanctions and Certain Other National Security Programs from 5 to 10 Years and...

While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more

Fenwick & West LLP

Sanctions Violations: New 10-Year Statute of Limitations

Fenwick & West LLP on

On April 24, 2024, President Biden signed into law an emergency supplemental appropriations law, H.R. 815 (Public Law 118-50), that provides substantial military aid to Ukraine, Israel, and Taiwan and could force the sale of...more

Mayer Brown

US Congress Extends Statute of Limitations for Sanctions and Export Controls

Mayer Brown on

On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the “Act”). While much of the focus centered on the foreign aid package for Israel, Ukraine, and the Indo-Pacific, the bill...more

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