OFAC Statute of Limitations Update

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The Department of the Treasury’s Office of Foreign Assets Control, (OFAC) put on public inspection Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years, consistent with the extension of the statute of limitations for violations of certain sanctions administered by OFAC.

OFAC is issuing this interim final rule to amend the Reporting, Procedures and Penalties Regulations (the “Regulations”), extending recordkeeping requirements for certain transactions from five to 10 years, consistent with the statute of limitations for violations of certain sanctions administered by the Office of Foreign Assets Control (OFAC).

This new 10-year statute of limitations applies to any violation that was not time-barred at the time of its enactment. Consequently, OFAC may now commence an enforcement action for civil violations of IEEPA- or TWEA-based sanctions prohibitions within 10 years of the latest date of the violation if such date was after April 24, 2019. As set forth in the Act, the commencement of a civil enforcement action includes the issuance of a pre-penalty notice or a finding of violation.

OFAC also put on public inspection a Comment Request for Reporting, Procedures and Penalties Regulations and Other Information Collections Maintained by OFAC for comments concerning OFAC's information requirements.

Reporting, Procedures and Penalties Regulations

 

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