In March of 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) introduced updated record retention requirements aimed at enhancing enforcement of economic and trade sanctions. These new rules are significant for businesses, financial institutions, and individuals who engage in transactions subject to U.S. sanctions laws.
Previously, under OFAC’s existing regulations, most parties were required to maintain records related to compliance for at least five years. The new requirements, effective March 21, 2025, now extend the record retention period from five to ten years for certain categories of records. This extension is designed to align OFAC’s policies with evolving global compliance standards and to provide the agency with greater visibility into historical transactions that may involve sanctions violations.
The updated retention requirements apply to:
These entities must retain records of all transactions, licenses, blocked property reports, communications with OFAC, and compliance documents for at least ten years from the date of the transaction or event.
The extended recordkeeping timeframe reflects a broader regulatory trend toward longer audit windows and increased transparency. OFAC has cited several key reasons:
Organizations need to immediately assess and, if necessary, update their internal compliance and document retention policies. This includes:
These records must be readily accessible and capable of being provided to the agency upon request, which may require updates to indexing and retrieval systems.
Failure to comply with the updated retention requirements can result in civil or criminal penalties, particularly if an inability to produce records hinders an OFAC investigation. In recent years, enforcement actions have increasingly included penalties for poor compliance infrastructure, not just for illegal transactions themselves.
The new OFAC record retention rules are more than just a bureaucratic update—they represent a strategic shift in enforcement philosophy. Organizations should view this as an opportunity to review and strengthen their sanctions compliance programs and ensure that all relevant records are retained, stored, and monitored appropriately for the full ten-year period.
With the rising complexity of international transactions and increased scrutiny on sanctions compliance, robust recordkeeping is not just a best practice, it’s now a regulatory necessity.
Have questions or want to know more? Contact ViClarity’s Compliance Services team at compliancesupport@viclarityus.com.
For more information, email Heather Line.
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For more information, email Lisa Quaranta.
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