forum.JEZIORA.com

[soumitss]

If I discover old OFAC violations from years ago, do I still need to report them? Or are they past the statute of limitations?

[hydrogenn]

OFAC has a 5-year statute of limitations, so violations older than that generally can't be penalized. However, finding old violations raises questions about whether similar issues are ongoing. Even if time-barred, consider what it says about your compliance program and whether current procedures are adequate. You're not legally required to report time-barred violations, but if they indicate systemic problems, addressing them is smart. Document your review of the historical issues and any remedial steps taken. I analyzed this situation at this link ofacblockedfundslawyers.com when we found old potential issues. Consider legal consultation to evaluate disclosure obligations and compliance improvements needed.