OFAC Issues Guidance on Extension of the Statute of Limitations

On July 22, 2024, the Office of Foreign Assets Control (OFAC) issued guidance to address "questions raised by recent legislation that extended the statute of limitations" for violations of certain sanctions programs administered by OFAC.

On April 24, 2024, the 21st Century Peace through Strength Act was signed into law, which extended the statute of limitations from five years to 10 years for both civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) or the Trading with the Enemy Act (TWEA).

According to the guidance from OFAC, this extension of the statute of limitations applies to violations that were committed after April 24, 2019. Additionally, OFAC said that to match the new statute of limitations, it plans to soon publish an interim final rule to extend its sanctions-related recordkeeping requirements from five to 10 years.

The published guidance can be found here:
https://ofac.treasury.gov/media/933056/download?inline