News & Analysis as of

Statute of Limitations Sanction Violations Office of Foreign Assets Control (OFAC)

Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period... more +
Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period usually commencing from the date of the wrong or injury or the discovery of the wrong or injury. Except for under a limited set of circumstances, if an individual does not file a suit within the specified time period, the law bars them from ever suing on that claim. less -
Faegre Drinker Biddle & Reath LLP

New (and Extended) Statute of Limitations for Many Sanctions Violations Enforced by OFAC

New OFAC Guidance on Statute of Limitations - On July 22, 2024, the Office of Foreign Assets Control (OFAC) published new guidance addressing how it intends to apply a recent change in the statute of limitations for...more

Hogan Lovells

OFAC issues statute of limitations guidance for US sanctions violations and recordkeeping

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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

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

Fenwick & West LLP

OFAC Publishes Guidance on 10-Year Sanctions Violations Statute of Limitations

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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

Locke Lord LLP

OFAC Doubles Statute of Limitations ‎for Sanctions Violations

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On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...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

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

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

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

Hogan Lovells

Statute of limitations extended for violations of U.S. sanctions

Hogan Lovells on

Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.  Companies should be aware of the...more

Kelley Drye & Warren LLP

Statute of Limitations for Sanctions Violations Increased to Ten Years

On April 24, 2024, the 21st Century Peace Through Strength Act became law. Although the Act contains many key national security policies, including aid for Ukraine and Israel, one provision that has been overlooked is a...more

King & Spalding

New Ten-Year Statute of Limitations for Sanctions Violations

King & Spalding on

Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more

Vinson & Elkins LLP

Not So Fast: Congress Doubles Statute of Limitations Period for U.S. Sanctions Violations in Foreign Aid Bill

Vinson & Elkins LLP on

Following months of delays and intense debate in Congress, President Biden signed H.R. 815 into law on April 24, 2024, which made headlines for funding $95 billion in military aid to Ukraine, Israel, and Taiwan, along with...more

Sheppard Mullin Richter & Hampton LLP

Say SoL Long to Short Limits: Doubling Down on the Sanctions Statute of Limitations

Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more

Adams and Reese LLP

International Compliance Digest – April 2024

Adams and Reese LLP on

April was another month of robust trade actions aimed at foreign goods, export compliance, and heightened enforcement powers. DHS issued an enhanced strategy policy on the textile industry with a focus on de minimis...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

Bass, Berry & Sims PLC

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

Bass, Berry & Sims PLC on

•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - April 2017

ANTICORRUPTION DEVELOPMENTS – Former Magyar Telekom Executives Settle Bribery Charges – On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more

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