Questions abound on foreign aid bill change to sanctions violations lookbacks

Tucked deep inside the $95 billion foreign aid bill recently passed by Congress was a provision that escaped notice among talk of providing military assistance to U.S. allies Ukraine, Israel, and Taiwan.

The bill (H.R.815) included a change to U.S. sanctions law: Investigators from the Treasury Department’s Office of Foreign Assets Control (OFAC) can now look back 10 years to investigate potential violations of U.S. sanctions, rather than five years.

“It really is a big change that shows that Congress is focusing on the mechanics of sanctions, for better or worse,” said Laura Deegan, counsel at law firm Miller & Chevalier who was previously a sanctions regulations advisor in OFAC’s regulatory affairs division.