OFAC Working on Guidance for New Sanctions Statute of Limitations
The Office of Foreign Assets Control plans to issue guidance on a law signed by President Joe Biden in April that extended the statute of limitations on certain sanctions violations from five to 10 years (see 2404290071 and 2404240043), Baker McKenzie said in a client alert this week. The law firm recently hosted a talk with OFAC official Lawrence Scheinert who said the agency is “working through the relevant legal issues” and plans to issue guidance about how the “change will be implemented,” Baker McKenzie said.
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Scheinert, OFAC's associate director for compliance and enforcement, also said the agency is seeing an uptick in voluntary disclosures. Disclosures are “more likely to lead to successful outcomes” if, among other things, they identify other parties involved in a potential sanctions violation, include the disclosing party’s “viewpoint on the narrative behind questionable transactions," and provide a full disclosure report “within a reasonable period after an initial notice is submitted to OFAC,” Scheinert said, according to the law firm.