• Share

    1. URL

[DR & AJU Issue Report] Enactment of U.S. H.R. 815 Extends Statute of Limitations for Violations of Economic Sanctions Laws

1. Background


On April 24, 2024, U.S. President Joe Biden signed into law a national security package (H.R.815) that includes aid to Ukraine, Israel, and Taiwan and economic sanctions against Iran and Russia.

Following Russia's invasion of Ukraine in 2022, the U.S. government issued Executive Order 14024, which designates over 2,000 individuals and entities involved in the Ukraine war as targets for economic sanctions. The country continued to strengthen pressure on Iran and Russia through various economic sanctions. The passage of the package also stands in line with these efforts.


2. Main Contents


The package includes doubling the statute of limitations for violations of economic sanctions laws, extending it from 5 years to 10 years.

Specifically, it amends the foundational laws for U.S. economic sanctions, the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA), to extend the statute of limitations for violations of both acts.

However, the package’s enactment does not impact the five-year statute of limitations for violations of export controls under the Export Control Reform Act or the Arms Export Control Act.


3. Implications

The extended statute of limitations is expected to have a broad impact on various aspects, such as mergers and acquisitions with U.S.-sanctioned companies, transaction due diligence, and other inter-corporate dealings. Korean companies will need to proactively strengthen their compliance efforts to mitigate the associated risks.


To respond to the rapidly evolving legal market, DR & AJU LLC has been publishing issue reports that analyze the latest news and trends in the legal landscape.

Please click the link below to access the report