Answer:
The manual requesteth and the manual explaineth. From page 146, document, not pdf:
The record retention requirements (i.e., five-year requirement to retain relevant OFAC records; for blocked property, record retention for as long as blocked; once unblocked, records must be maintained for five years).
These are the records required by law, but they are relevant only if you have faced these circumstances. You might also keep records to indicate that your procedures are followed, that you verify that your OFAC software has been updated, etc.
First published on BankersOnline.com 12/14/09
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