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On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule (Final Rule) extending the recordkeeping requirement for compliance with U.S. economic sanctions regulations from five to 10 years. This change aligns with the April 2024 legislation (Pub. L. 118-50) that increased the statute of limitations for economic sanctions violations under the International Emergency Economic Powers Act (IEEPA), 50 U.S.C. § 1705, and the Trading with the Enemy Act (TWEA), 50 U.S.C. § 4315 to 10 years. The Final Rule took effect March 21, 2025.

Click here to read the full GT Alert.

Tags: department of treasury, economic sanctions, GT Insight, OFAC
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Photo of Kara M. Bombach Kara M. Bombach

Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and

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Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Russia), entities and individuals. In cases of foreign investment in the United States, Kara advises on the Exon-Florio provisions relating to U.S. national security concerns. She represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations.

Kara regularly represents clients in matters before U.S. government agencies, including the U.S. Departments of Commerce, State, Treasury and Defense. Kara has significant experience representing individuals and entities before OFAC in delisting matters and challenges to OFAC sanctions designations.

She advises national and multi-national companies (including Fortune® 5) on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anti-corruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.

Kara also counsels international not-for-profit and relief/aid organizations on best practices in economic sanctions, trade, and anti-corruption compliance issues that arise in their global operations, frequently in challenging and austere environments. She has provided legal services to organizations such as Save the Children (US), ONE Campaign, Mercy Corps, the International Committee of the Red Cross, Not on Our Watch/The Sentry, and The Enough Project.

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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Miranda R. Carnes Miranda R. Carnes

Miranda R. Carnes focuses her practice on navigating cross-border disputes and compliance, including international litigation and arbitration, International Trade regulation, and public international law. In International Trade matters, she counsels clients on U.S. export controls and economic sanctions, antidumping and countervailing duty investigations…

Miranda R. Carnes focuses her practice on navigating cross-border disputes and compliance, including international litigation and arbitration, International Trade regulation, and public international law. In International Trade matters, she counsels clients on U.S. export controls and economic sanctions, antidumping and countervailing duty investigations, and customs matters. She advises clients on a range of economic sanctions and export controls issues, including those arising under sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the International Traffic in Arms Regulations (ITAR), and the Export Administration Regulations (EAR).

In international litigation matters, Miranda represents clients in U.S. proceedings to obtain discovery for use in foreign litigations and to enforce (or defend against the enforcement of) foreign judgments and arbitration awards. She also represents clients before OFAC and the International Criminal Police Organization (INTERPOL) in connection with cross-border criminal investigations. These proceedings generally have a Latin America focus.

Finally, Miranda helps advise governments on matters raising issues of public international law, including international humanitarian law, the law of the sea, and obligations that arise from multilateral and bilateral treaties.

Read more about Miranda R. CarnesMiranda R.'s Linkedin Profile
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Photo of Cyril T. Brennan Cyril T. Brennan

Cyril (Cy) Brennan focuses his practice on international trade regulation and compliance, with an emphasis on U.S. export controls and economic sanctions. Cy handles matters regarding the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), U.S. sanctions programs administered by…

Cyril (Cy) Brennan focuses his practice on international trade regulation and compliance, with an emphasis on U.S. export controls and economic sanctions. Cy handles matters regarding the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), U.S. sanctions programs administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s anti-boycott regulations. In addition, he represents clients before the Committee on Foreign Investment in the United States (CFIUS), and advises clients on the Foreign Corrupt Practices Act (FCPA), the foreign direct investment reporting requirements of the Bureau of Economic Analysis (BEA), and other trade and investment-related regulations in the context of mergers and acquisitions.

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Photo of Sonali Dohale Sonali Dohale

Sonali Dohale assists companies engaged in international business navigate U.S. international trade laws and regulations. She counsels clients on a range of economic sanctions and export controls issues, including those arising under sanctions programs administered by the U.S. Department of the Treasury’s Office…

Sonali Dohale assists companies engaged in international business navigate U.S. international trade laws and regulations. She counsels clients on a range of economic sanctions and export controls issues, including those arising under sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the International Traffic in Arms Regulations (ITAR), and the Export Administration Regulations (EAR). Sonali advises on IEEPA tariff recovery and also represents companies engaged in cross-border mergers and acquisitions before the Committee on Foreign Investment in the United States (CFIUS). Her practice also involves assisting companies with internal investigations and compliance programs under various anti-corruption regimes (including the U.S. Foreign Corrupt Practices Act (FCPA) and World Bank’s Integrity Compliance Guidelines).

Sonali is a member of the firm’s Tariff Task Force, a multidisciplinary initiative that draws on the firm’s global platform to guide our clients through what comes next in regards to tariffs, including tariff refund matters, tax, litigation, and M&A activity spurred by these global shifts.

Sonali has represented companies before a number of U.S. agencies and federal courts, including the U.S. Departments of the Treasury, State, and Commerce, the U.S. International Trade Commission, the U.S. Court of International Trade, and the U.S. Court of Appeals for the Federal Circuit.

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