United States v. $8,221,877.16 in U.S. Currency, 330 F.3d 141 (3rd Cir. 2003) The statute of limitation for the institution of an action to seize substitute assets under 18 U.S.C. § 984 is one year.United States v. Estate of Parsons, 367 F.3d 409 (5th Cir. 2004) During the direct appeal of his conviction, the defendant died. The en banc Fifth Circuit concludes that the criminal forfeiture order, as well as the sentence of restitution abated upon the defendant’s death.