31 CFR §501.601 — Records and recordkeeping requirements

ofac-31cfr-501-601

OFAC recordkeeping rule. Every person engaging in any transaction subject to the OFAC sanctions regulations (31 CFR chapter V) must keep a full and accurate record of each such transaction for at least 10 years; every person holding blocked property must keep a full and accurate record of that property while it is blocked and for 10 years after it is unblocked.

Get this register: .xlsx .csv More bundles →

source:
  type: regulation
  id: ofac-31cfr-501.601
  authority: 31 CFR §501.601 — Records and recordkeeping requirements
  description: |
    OFAC recordkeeping rule. Every person engaging in any transaction
    subject to the OFAC sanctions regulations (31 CFR chapter V) must
    keep a full and accurate record of each such transaction for at
    least 10 years; every person holding blocked property must keep a
    full and accurate record of that property while it is blocked and
    for 10 years after it is unblocked.
obligations:
  - id: ofac-31cfr-501.601-10-year-transaction-records
    canonical_id: ofac-31cfr-501.601-10-year-transaction-records
    section: 31 CFR §501.601 — 10-year transaction recordkeeping
    description: |
      Except as otherwise provided, [LENDER] (as a person engaging in any
      transaction subject to 31 CFR chapter V) shall keep a full and
      accurate record of each such transaction engaged in, regardless of
      whether the transaction is effected pursuant to license or
      otherwise. Such record shall be available for examination for at
      least 10 years after the date of the transaction. Where [LENDER]
      holds property blocked pursuant to 31 CFR chapter V (or funds
      transfers retained under §596.504(b)), [LENDER] shall keep a full
      and accurate record of the property and make it available for
      examination for the period that the property is blocked and for at
      least 10 years after it is unblocked.
    type: do
    audit_question: For any OFAC-relevant transaction (including blocking, rejection, or license-authorized payment), can [LENDER] produce a full and accurate record on demand, retained for at least 10 years from the transaction date (or for the duration of the block plus 10 years after unblocking)?
    program_review: Do the P&Ps ensure a full and accurate record of each OFAC-relevant transaction (blocking, rejection, or license-authorized payment) is kept and available for examination for at least 10 years from the transaction date — and, for blocked property, for the duration of the block plus 10 years after unblocking?
    file_review: For sampled OFAC-relevant transactions (blocks, rejects, licensed payments), confirm a full/accurate record retained for the 10-year (or block-duration + 10-year) period.
    judgment: false
    feeds: []
    workflow_phase: origination
    owner_role: compliance_officer
    secondary_owner_role: bsa_aml_officer
    cadence: continuous
    consequence: ''
    tags:
      - round-b
      - regulator-direct
      - ofac
      - treasury
      - sanctions
      - recordkeeping
      - 10-year-retention
      - promoted
    primary_source:
      tier: 1
      authority: 31 CFR §501.601
      source_class: ofac-treasury
      source_url: https://www.law.cornell.edu/cfr/text/31/501.601
      snapshot_id: 67ade058e823cbee
      fetched_at: '2026-05-22T11:34:28Z'
      content_hash: sha256:e93d6349f1422f3d1c0712402f04c5eb0bdfd7f83ed0e5b9a801a48f1fc62752
      paragraph_quote: Except as otherwise provided, every person engaging in any transaction subject to the provisions of this chapter shall keep a full and accurate record of each such transaction engaged in, regardless of whether such transaction is effected pursuant to license or otherwise, and such record shall be available for examination for at least 10 years after the date of such transaction.
      drafter_attestation: |
        Copied verbatim from snapshot 67ade058e823cbee (content.txt) at
        2026-05-22T11:40Z. Substring is the first operative sentence of
        §501.601; the blocked-property record sentence is paraphrased in
        description.
    promoted_at: '2026-05-22T12:13:32+00:00'
    promoted_from: ofac-31cfr-501.601-roundb-v1.yaml
_promotion_history:
  - promoted_at: '2026-05-22T12:13:32+00:00'
    candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\_round_b_drafts\ofac-31cfr-501.601-roundb-v1.yaml
    candidates_promoted: 1
    candidates_skipped_existing: 0

Verbatim regulatory text (1)

Verbatim provisions from 31 CFR §501.601 — Records and recordkeeping requirements — each quote is a verified substring of the regulator-published source snapshot, not retyped. Quoted for reference; this is not legal advice. The operational layer (P&P updates, prompts) lives in the regulation update kits.

31 CFR §501.601 — 10-year transaction recordkeeping

Except as otherwise provided, every person engaging in any transaction subject to the provisions of this chapter shall keep a full and accurate record of each such transaction engaged in, regardless of whether such transaction is effected pursuant to license or otherwise, and such record shall be available for examination for at least 10 years after the date of such transaction.

Source: 31 CFR §501.601 · source URL · snapshot 67ade058e823cbee