Leela
Sanctions / OFAC
SO-09

Retain screening, investigation, and blocking records for five years

Policy reference

Sanctions / OFAC policy, §6

Reporting, Procedures and Penalties Regulations, records and recordkeeping requirements, 31 CFR 501.601
Requirement

Every screening run on every surface, every match workpaper, every hold or blocking action with its timestamps, every suppression with its justification, and every sponsor bank notification is retained for at least five years. Blocked-property and blocking records are kept for at least five years from the transaction date, or the longer period OFAC regulations require, in a format that can be produced for the sponsor bank or an examiner.

Trigger

Continuous

Five years from each record; from the transaction date for blocking records

Action

File each screening run, workpaper, hold or block, suppression, and notice under the retention schedule with its retention date, and be able to produce any of them on request.

Evidence
  • Retention schedule entry

    Record class, retention period and start date, location

  • Suppression log

    Kept for the life of each suppression plus five years

Owner

AML Compliance Officer

Leela can
Monitor

Leela can watch for the trigger, keep the clock, and flag what is late.

Leela can file each screening run, workpaper, and notice with its retention date and prove it on request.

Applies

Tell Leela about your company to see whether this applies.

Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

What’s next?