The Office of Foreign Assets Control released guidance this week announcing plans to issue an interim final rule to extend recordkeeping requirements from five years to 10 years, likely with an effective date six months after publication. The proposed changes stem from the passage of the 21st Century Peace through Strength Act earlier this year, which extends the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act, or IEEPA, or the Trading with the Enemy Act, TWEA.
Also, because the new law became effective on April 24, OFAC’s new guidance states that the office intends to apply the new 10-year statute of limitations for IEEPA or TWEA to civil violations that occur after April 24, 2019.
