OFAC has issued guidance on recent legislation that doubled the statute of limitations for certain sanctions violations to 10 years, under the International Emergency Economic Powers Act (‘IEEPA’) or the Trading with the Enemy Act (‘TWEA’). OFAC said, “‘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 ...
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