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Five-Year Record Retention Requirement for Export Transactions Under Review

Tuesday, April 29, 2014
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security is soliciting through May 29 comments on the requirement for all parties involved in export transactions and the U.S. party involved in boycott actions to maintain records of these activities for five years. These records may be retained in an electronic format or in paper form and include export control documents and other documents described in section 762 of the Export Administration Regulations. The five-year record retention period corresponds with the five-year statute of limitations for criminal actions brought under the International Emergency Economic Powers Act, the Export Administration Act of 1979 and predecessor acts, and the five-year statute for administrative compliance proceedings.

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