Congress quietly caps export enforcement at 10 years, shielding old violations
H.R. 8202 — To amend the Export Control Reform Act of 2018 to provide for a ten-year statute of limitations for export control violations. · Filed by Ryan Mackenzie (R-PA) · 3 cosponsors · Introduced Apr 6, 2026 · Reported out
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What it does
This bill amends the Export Control Reform Act of 2018 to establish a 10-year statute of limitations for both civil enforcement actions and criminal prosecutions related to export control violations. Currently, no time limit exists; this bill caps the window during which the government can pursue civil penalties, fines, forfeitures, or criminal charges for illegal exports at 10 years from the date of the violation.
Why we flagged it
The bill's sole operative function is to cap the government's enforcement window for export control violations at 10 years, narrowing prosecutorial reach and creating a time-based safe harbor for older violations.
What the text implies
- A 10-year statute of limitations may be insufficient for complex export schemes involving multiple shipments, shell companies, or delayed discovery of violations — sophisticated smuggling networks often operate across years before detection.
- The bill does not distinguish between minor technical violations and serious proliferation offenses (e.g., illegal sales of dual-use technology to sanctioned regimes), applying the same deadline to both.
The full analysis lists 4 implications of this text.
Who stands to gain
export-oriented companies and trading firms; defense contractors and dual-use technology suppliers; entities engaged in sanctions evasion or proliferation-adjacent trade