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Five-Year Record Retention Requirement for Parties to Export Transactions Under Review

Thursday, January 16, 2014
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security is soliciting comments through March 17 on the requirement for all parties involved in export transactions and the U.S. party involved in a boycott action to maintain records of these activities for five years. These records can include memoranda, correspondence, contracts, invitations to bid, books of account, financial records, restrictive trade practice or boycott documents and reports. The five-year record retention period corresponds with the five-year statute of limitations for criminal actions brought under the Export Administration Act of 1979 and predecessor acts as well as the five-year statute for administrative compliance proceedings.

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