The Office of Foreign Assets Control today issued a final rule extending recordkeeping requirements for certain transactions from five to 10 years to make them consistent with the recently expanded statute of limitations for sanctions violations. This 10-year recordkeeping requirement went into effect on March 12 under OFAC’s interim final version of the rule.
Congress last year passed the 21st Century Peace Through Strength Act, which contained multiple provisions related to various foreign policy matters. Included in the legislation was a provision that doubled the statute of limitations for civil and criminal violations of the International Emergency Economic Powers and the Trading with the Enemy Act. The final rule updates OFAC’s recordkeeping requirements to be consistent with the new statute of limitations.
