Record Keeping of OFAC Screen Prints

Question:

At our bank we have to do screen prints of when we do OFAC checks. How long do you advise that we hold these copies for?

Answer:

BSA’s record retention requirements do not apply to OFAC; there is no legal bridge between the two regulatory frameworks. As there is no legal requirement that you check the OFAC list, you only do it as a precaution, there is no legal requirement that you retain records of the fact that you have done so.

Any record retention you engage in regarding your new account process or full file comparisons to the OFAC list are in an effort to document your compliance with your own procedures. At most, the record retention period would be "between examinations."

Some banks wove references to checking the OFAC list into their CIP and, inadvertently, made their processes subject to CIP's requirement for 5 year record retention.

First published on BankersOnline.com 1/23/06