In this article, Laura Deegan commented on the implications of recent legislation that doubles the statute of limitations under the International Emergency Economic Powers Act (IEEPA) and the Trading With the Enemy Act. Companies could now encounter difficult questions from authorities if they investigate conduct older than five years. "It might be difficult to explain the circumstances or refute what happened if you don't have any sort of record surrounding what happened on your side," Deegan said. "So it almost could force companies to increase their record retention requirements to meet the ten years." She also noted that companies that sign tolling agreements, in which defendants agree to delay proceedings to give authorities more time to collect evidence, often receive "some sort of goodwill" that contributes toward earning a cooperation credit during settlement negotiations. With a ten-year statute of limitations, she said, companies may not receive tolling agreements as often, taking away one avenue toward the credit.