+7 495 139 4000
News and publications
Longer Statute of Limitations on Violations of U.S. Sanctions Laws: What You Need to Know
At the end of April 2024, legislation ("H.R. 815 Act") was enacted in the U.S. providing for the extension of statute of limitations on violations of sanctions laws from 5 to 10 years.

This change applies to violations of sanctions imposed under the International Emergency Economic Powers Act ("IEEPA") and the Trading with the Enemy Act ("TWEA"). These sanctions also include the major sanctions regimes against the Russian Federation.

In July 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued guidelines clarifying that the new statute of limitations applies to violations committed after April 24, 2019, i.e., violations for which the limitation period had not expired when the amendments became effective. OFAC may bring civil and criminal proceedings for such a violation within the new ten-year period.

The H.R. 815 Act specifies that such proceedings include a preliminary notification of imposed penalty or violation. This gives OFAC significantly more time to investigate violations of the sanctions laws.

OFAC also plans to issue supplemented regulations extending the document retention and record-keeping requirements for sanction-affected transactions from 5 to 10 years.

These changes increase the risk of potential liability for sanctions violation and show once again that the US tighten control over such violations.

#sanctions
Read also
09/5/2025
International Day of Charity
#pro_bono
Today, the whole world celebrates International Day of Charity, and it’s a wonderful occasion to remember how much we can achieve together! At KKMP, we believe that good deeds are what make the world brighter, and we strive to contribute every day.
09/4/2025
Preferential Purchase of an LLC Share: A Shift to Flexible Rules
#news
Since September 1st, LLC participants have significantly more freedom in regulating the preemptive right to purchase a share, up to and including its complete cancellation. A material on this change in legislation has been published on the analytical portal Pravo.ru.
09/4/2025
August International Digest: Easing of Asset Unblocking and a Ban on Enforcement of Judgments
#news
In August, several countries expanded their sanction lists to include Russian individuals and companies, and the US applied a new mechanism of secondary sanctions for the first time. Simultaneously, opportunities are emerging for the exchange of frozen assets. Cyprus has begun issuing the first licenses for asset withdrawal, and in Russia, the Central Bank has allowed foreigners to use funds in Type "C" accounts.