How long must I keep sanctions screening records?

5 years per OFAC and FinCEN requirements. This applies to screening logs, alert dispositions, blocking reports, and training records.

What must an AI agent screening log contain?

Transaction ID, counterparty, result, SDN list version, timestamp, agent ID, and action taken.

Can audit trails be digital?

Yes. Digital records are acceptable if they are complete, accurate, and readily retrievable. Most institutions use digital-only audit trails.

What happens if I cannot produce records during an OFAC exam?

Failure to maintain records is a sanctions violation. Civil penalties up to $356,571 per violation. Document any records that cannot be produced and explain why.

Sanctions compliance audit trail retention period

Your audit trail is your compliance evidence. OFAC and FinCEN require 5-year retention of all sanctions-related records.

What constitutes an audit trail

For AI agents

AI agent screening decisions must be logged with: (1) transaction identifier, (2) counterparty screened, (3) screening result (clean/blocked), (4) SDN list version, (5) timestamp, (6) agent identifier, (7) action taken (proceed/block).

Record	Contents	Retention
Screening log	Subject, timestamp, result, SDN list version, API response	5 years
Alert disposition	Alert details, reviewer, decision, rationale, timestamp	5 years
Blocking/rejection records	Transaction details, SDN match, report filed	5 years
Training records	Attendee, date, content, completion	5 years
Risk assessments	Document, date, approval, next review	5 years

SanctionsAI logging: Every API call is logged with timestamp, subject, result, and list version. The audit trail is available via the dashboard and exportable for compliance reviews.

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Frequently Asked Questions

How long must I keep sanctions screening records?: 5 years per OFAC and FinCEN requirements. This applies to screening logs, alert dispositions, blocking reports, and training records.
What must an AI agent screening log contain?: Transaction ID, counterparty, result, SDN list version, timestamp, agent ID, and action taken.
Can audit trails be digital?: Yes. Digital records are acceptable if they are complete, accurate, and readily retrievable. Most institutions use digital-only audit trails.
What happens if I cannot produce records during an OFAC exam?: Failure to maintain records is a sanctions violation. Civil penalties up to $356,571 per violation. Document any records that cannot be produced and explain why.