Ten-Year Statute of Limitations for US Sanctions Violations

The ten-year statute of limitations is the period during which US authorities can pursue a civil or criminal violation of sanctions based on IEEPA (International Emergency Economic Powers Act) or the Trading with the Enemy Act. Section 3111 of the 21st Century Peace through Strength Act, passed in the national security package signed on April 24, 2024, raised it from five to ten years. It applies to any violation not already time-barred on that date, so to conduct after April 24, 2019. OFAC (Office of Foreign Assets Control) followed suit on records. An interim final rule published on September 13, 2024 extends the recordkeeping duty in 31 CFR (Code of Federal Regulations) 501.601 to ten years, effective March 12, 2025 and confirmed by a final rule published on March 21, 2025. Blocking reports, licenses and correspondence about a sanctions-subject transaction therefore have to remain available for ten years. For an insurer, the change hits archives first. Many internal retention policies for claims files were set on the local civil limitation period or on five years. A 2020 settlement with a payee later found in 2028 to have been blocked can still be pursued, and the defense rests on screening that has to be shown. The decision to disclose changes too: a violation discovered late is no longer close to expiring, and waiting no longer protects anyone. A loss portfolio transfer or a run-off that takes on old files takes on with them a sanctions exposure the sellers thought closed after five years, and the indemnity in the deal has to address it. EU law, which leaves criminal limitation periods to member states, runs on a different calendar, and a European group has to keep both.