Sanctions / OFAC
SO-09Retain screening, investigation, and blocking records for ten years
How Leela would run itContinuous · ten years from each record or transaction; blocked property while blocked and ten years after unblocking
From the policy libraryThe 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 ten years. Transaction records are kept for at least ten years after the transaction, and blocked-property records for as long as the property stays blocked and at least ten years after it is unblocked, in a format that can be produced for the sponsor bank or an examiner.
- 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.
The work
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.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Retention schedule entryRecord class, retention period and start date, location
- 02Suppression logKept for the life of each suppression plus ten years
Evidence
Retention schedule entry
Sanctions / OFAC §6
2
of 2 records
The work and the records come from this obligation in the policy library.