What changed
- Legislation signed April 24, 2024 extended the statute of limitations for IEEPA and TWEA sanctions violations from 5 to 10 years.
- OFAC amended its recordkeeping rules so covered records must be kept for 10 years, effective March 17, 2025.
- OFAC continues to issue frequent designation updates, so a counterparty that was clean at onboarding may not stay clean.
Who's affected
Any US person or business — including fintechs, MSBs, exporters, and law firms — that screens against OFAC lists.
What compliance teams should do now
- Store a dated record of every screen and its outcome, not just the final decision.
- Re-screen existing customers and counterparties when OFAC lists change.
- Make sure records can be exported and read without the tool that created them.
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How AMLX helps
AMLX produces dated PDF exports of screening results and case notes, and Pro watchlists flag when a monitored name picks up a new sanctions hit.
Built for: Fintech & Payments · Banks & Credit Unions · Law Firms & Advisors · Insurers & Marketplaces · Money Services Businesses & Remittance
Jurisdiction coverage: United States screening · Mexico screening
Related regulatory updates
- FinCEN's 2026 AML/CFT Program Rule Overhaul — FinCEN has proposed a fundamental, risk-based reform of AML/CFT program requirements for every BSA-covered financial institution.
- Investment Adviser AML Rule Delayed to 2028 — FinCEN pushed its investment adviser AML/CFT rule from January 1, 2026 to January 1, 2028 — but the delay is a runway, not an exemption.
- FinCEN Residential Real Estate Rule Vacated — The FinCEN Residential Real Estate Rule took effect March 1, 2026 and was vacated by a federal court in Texas on March 19, 2026. Laundering risk in all-cash deals did not go anywhere.
Frequently asked questions
What is the OFAC 10 year recordkeeping requirement change?
Sanctions violations can now be pursued for 10 years, and OFAC extended recordkeeping to match. Your screening evidence has to last a decade.
Who does this affect?
Any US person or business — including fintechs, MSBs, exporters, and law firms — that screens against OFAC lists.
How can AMLX help us respond?
AMLX produces dated PDF exports of screening results and case notes, and Pro watchlists flag when a monitored name picks up a new sanctions hit. You can start on the free tier with no sales call.
Sources
This page summarises public regulatory developments for general information. It is not legal advice; confirm current status with the regulator or your counsel.