Back in March 2025, the Department of the Treasury’s Office of Foreign Asset Control (OFAC) issued a Final Rule that extended certain recordkeeping requirements related to OFAC compliance.
Specifically, the time period for which institutions must maintain records of any transaction engaged in that is subject to sanctions and/or for any blocked or retained property was increased from 5 years to 10 years. The recordkeeping requirements in 31 CFR 501.601 now state:
Except as otherwise provided, every person engaging in any transaction subject to the provisions of this chapter shall keep a full and accurate record of each such transaction engaged in, regardless of whether such transaction is effected pursuant to license or otherwise, and such record shall be available for examination for at least 10 years after the date of such transaction. Except as otherwise provided, every person holding property blocked pursuant to the provisions of this chapter or funds transfers retained pursuant to §596.504(b) of this chapter shall keep a full and accurate record of such property, and such record shall be available for examination for the period of time that such property is blocked and for at least 10 years after the date such property is unblocked.
While the chances of an institution having a legit OFAC hit are often low and the need to block property even smaller, BSA personnel need to be aware of this change. We are finding that this seemed to fly under the radar and many institutions are not aware of it.
It’s also likely that your written OFAC policy and procedures reference the OFAC record retention requirements, so make sure you update those as well.
Published 2026/01/28
