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31 CFR § 501.601 — Records and recordkeeping requirements (five years); OFAC Economic Sanctions Enforcement Guidelines, 31 CFR Part 501 App. A

OFAC sanctions screening record-keeping (31 CFR Part 501)

Every person engaging in any transaction subject to the provisions of this chapter shall keep a full and accurate record of each such transaction … and such record shall be available for examination for at least 5 years after the date of such transaction. source

Who it reaches

All U.S. persons; in practice every organization paying vendors, contractors or counterparties.

The record the rule expects

The OFAC SDN and Consolidated Screening List read by exact printed name on the transaction date, with the list's publication date, kept five years with the transaction record.

Questions readers ask

Exact-name only?

Yes. Rows under the exact printed name or alias as OFAC prints it. Fuzzy screening is a separate discipline and is not presented here as a match.

Why keep the receipt?

501.601's five-year record. A dated, hashed read of the list on the transaction date is the record of what the list printed that day.

This page quotes the rule and describes the record; whether your organization meets the rule is your compliance office's and counsel's reading. All rules · Methodology.

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