Tolling agreement definition

Tolling agreement

An agreement by a party under investigation to extend or suspend the statute of limitations, giving the regulator more time to finish before a deadline would otherwise bar action.

also known as

statute of limitations tolling agreement

reviewed

2026-10-02

Cite this page

APA 7

Sanctions Evasion Reference. (2026, October 2). Tolling agreement. https://sanctionsevasion.org/reference/glossary/tolling-agreement/

Chicago

Sanctions Evasion Reference. “Tolling agreement.” Last reviewed October 2, 2026. https://sanctionsevasion.org/reference/glossary/tolling-agreement/.

BibTeX

@misc{ser-reference-glossary-tolling-agreement,
  author = {{Sanctions Evasion Reference}},
  title  = {Tolling agreement},
  year   = {2026},
  note   = {Last reviewed 2026-10-02},
  url    = {https://sanctionsevasion.org/reference/glossary/tolling-agreement/}
}

The date is when this page was last reviewed, not when it was first published.

OFAC enforcement releases list agreeing to toll the statute of limitations among the ways a company cooperated. Investigations into conduct that ended years earlier can run past the limitation period, and a company that signs a tolling agreement keeps the case open in exchange for being seen as cooperative.

The releases on this site show how long that can run. UniCredit signed a tolling agreement “with multiple extensions” for conduct that ended by 2012 and settled in 2019. Nasdaq tolled for conduct that ended in 2014 and settled in 2023. In both, OFAC counted it as mitigating.

Where this term is used

How do gaps in acquisition integration create sanctions exposure? — A company buys a foreign business and keeps running its systems separately, so the acquired unit's transactions never pass through the parent's sanctions screening until someone thinks to connect them.
What happens when sanctions-screening controls go untested? — A firm builds real geo-blocking or screening controls, then never independently tests whether they still work, so a bug, a disabled setting or a discontinued tool runs unnoticed for months or years.

Related terms

Voluntary self-disclosure — A self-initiated notification to OFAC of an apparent violation, made before or at the same time as OFAC or another authority discovers it, which lowers the base penalty.
Egregious case — OFAC's label for a particularly serious violation calling for a strong enforcement response, which sets a much higher starting penalty than a non-egregious case.

Sources

Enforcement action: UniCredit Bank. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019. Penalty notice, 2019-04-15, US$611,023,421.

OFAC Settles with Nasdaq, Inc. for $4,040,923. U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Enforcement release, 2023-12-08, US$4,040,923.

Economic Sanctions Enforcement Guidelines, Appendix A to 31 CFR Part 501. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Sections I (definitions), II (responses), III (general factors), V.B (penalty calculation).