In a letter today, the American Bankers Association said that banks need further guidance from the Office of Foreign Assets Control about how to implement its new recordkeeping requirements, as they deviate from existing bank practices and requirements.
OFAC in March issued a final rule extending recordkeeping requirements for certain transactions from five to 10 years to make them consistent with the recently expanded statute of limitations for sanctions violations. ABA noted that, for the first time, banks must keep records for 10 years exclusively for the purpose of complying with the new sanctions recordkeeping requirements. The new mandate is in addition to existing regulatory requirements – such as Bank Secrecy Act recordkeeping rules – some of which only require records to be kept for five years.
“As banks adjust their records retention schedules, guidance regarding OFAC’s new expectations would assist banks, their sanctions compliance professionals, their bank examiners and primary regulators, and other important stakeholders understand the new recordkeeping requirements,” ABA said.
