Sanctions & Tariff Lookup
Sanctions screening records: what to keep and for how long
Last updated · Starry Night
If OFAC or an auditor asks how you screened a customer three years ago, the answer has to come from your files. Here is what the rules say and what a usable record contains.
What the rules say
- 31 CFR 501.601: every person engaging in a transaction subject to OFAC's regulations keeps a full and accurate record of it, available for examination for at least 10 years after the transaction. Records of blocked property are kept while it is blocked and for at least 10 years after it is unblocked. The period was raised from 5 to 10 years by an amendment published in 2024 (89 FR 74834).
- OFAC FAQ 5: keep complete, accurate records of the steps taken to investigate a potential match and the information relied on to decide it.
- OFAC FAQ 28: how often you screen is guided by your organization's internal policies. Write the schedule down so the records show it was followed.
What a screening record should show
- Date and time of the run.
- Every list screened, with its as-of date or version. Lists change weekly, so a result means little without it.
- The matching method and threshold.
- Every name screened, with its result.
- For each possible match: the list entry, what you compared, and the reason you cleared or escalated it.
- Who reviewed it, and when.
Keeping it manageable
- One folder per run (or per month), with the record and any supporting documents together.
- Note a hash or file name of each record in a log, so you can show it has not changed since filing.
- Set the retention period with counsel; 10 years is the OFAC floor for transaction records.
A dated record for every run
The screening record page screens up to 500 customers, suppliers or vessels at once against the U.S. Consolidated Screening List (OFAC, BIS and State Department lists), the UN Security Council Consolidated List, the UK Sanctions List and the EU consolidated financial sanctions list, with name matching that handles word order, transliteration variants and small typos, and builds a dated PDF record of the run. On-screen results and a PDF marked PREVIEW are free; a $29 one-time unlock removes the watermark for 24 hours. Names are not stored.
The PDF contains most of the list above: date and time, every list with its as-of date and the mirror data version, the method and threshold, every party with its result, each possible match with a link to the publisher's entry, a reviewed-by block and a SHA-256 of its content. It is generated in your browser and is not signed or kept by Starry Night. It documents that a screening was run and what it returned; it does not show that a party is or is not sanctioned.
Checking a few names while you work in Claude? The free Sanctions & Tariff Lookup connector screens a name from a chat and shows each possible match with its list, programs and identifiers. No sign-up with Starry Night is needed.
This guide explains public rules and OFAC guidance in plain English. It is not legal advice; for a decision about a specific party or transaction, talk to sanctions counsel or contact OFAC. Sanctions & Tariff Lookup is published by Starry Night and is not affiliated with OFAC, the Department of Commerce, the State Department, the UN, the UK government or the European Commission.
Questions
How long must OFAC records be kept?
At least 10 years after the date of the transaction, under 31 CFR 501.601 as amended in 2024 (89 FR 74834). Records of blocked property are kept while it is blocked and for at least 10 years after it is unblocked.
Do I have to keep a record of names that did not match?
The regulation covers records of transactions. OFAC FAQ 5 asks organizations to keep complete, accurate records of how they investigated potential matches. A dated record of each screening run is a simple way to show both.