March 25, 2025

OFAC amends Reporting, Procedures and Penalties Regulations

On March 21, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued a final rule to adopt an interim final rule published on September 13, 2024 that amends the Reporting, Procedures and Penalties Regulations.  The final rule extends certain recordkeeping requirements from five to 10 years in order to stay consistent with the statute of limitations for certain sanctions violations that OFAC administers, including the International Emergency Economic Powers Act, 50 U.S.C. 1701 et seq. (IEEPA).  While OFAC received and considered three comments regarding the interim final rule, OFAC made no revisions to the rule before it was adopted.

Federal Register – Final Rule