The US statute of limitations for sanctions violation prosecutions has been extended from five to ten years under federal legislation signed into law on 24 April 2024.
Companies with sanctions compliance programmes must now ensure they keep ten years of transactional and compliance data to navigate future enforcement cases.
The legislation also authorises the government to seize frozen Russian state-owned assets and use them to support Ukraine without the possibility of judicial review challenges.
It prohibits the release of frozen Russian sovereign assets in US financial institutions until the Russia-Ukraine war is over and full compensation has been made to Ukraine for damage resulting from it.
It also requires the government to impose sanctions against parties subject to EU or UK sanctions who are not yet designated under US sanctions.
