OFAC Screening Recordkeeping

The requirement to keep screening logs and compliance records for a minimum of five years so each decision can be reconstructed later.

TL;DR

TL;DR: Recordkeeping means retaining the logs that show what was screened, what matched, and what decision followed, for at least five years. These records are what you show OFAC if a transaction is ever questioned.

What to retain

OFAC expects records that show a screening check was performed and what it found. That includes the counterparty identifier, the list or entry that matched, the timestamp, and the ALLOW or BLOCK outcome. Records must be kept for at least five years and be retrievable, not just technically stored somewhere.

Why it matters for agent payments

An agent that screens and pays can produce millions of decisions in a short time. If the operator cannot reconstruct a specific decision months later, it has no way to demonstrate compliance for that payment. A screening API that logs every call with its result gives the agent a durable record without requiring the operator to build one from scratch.

Recordkeeping essentials

• Counterparty identifier and screening result
• Matched list entry, when one is found
• Timestamp and decision for every check
• Retention of at least five years

Making records usable

Records are only useful if they can be produced. Storage in a system that cannot search or export is a practical failure, because an OFAC inquiry arrives with specific questions about specific transactions. The logs should be queryable by counterparty, by date, and by decision, and they should survive personnel and system changes. Five years of retention means nothing if the records cannot be found when they are needed.