On a daily basis, we review a report which runs all ACH transactions against the SDN list. We print, make sure that none of them are matches (we haven't had one yet), initial to indicate a review, and file away.

How long do you believe these should be retained for? We can pull the reports from our system at any time, but for auditing purposes, we have hard copies with initials indicating they were reviewed. Our policy and procedure are silent on the retention period for this specific item.

Can you make notes on the report in your reporting software? We have a similar process and just initial them digitally - reduces paper and time printing.

Good thought, and we're going that way on a lot of these types of reports/auditing points. This does seem to be one more we can add.

That said, anyone have ideas on if we have to retain this for (for example) 5 years or anything?

Since you can retrieve them on you system, you may just want to keep them from the last exam as proof you are looking at it. If you decide to go the digital route, it will be a moot point.

This doesn't exacly answer your question but I would be hesitant to get rid of records less than 5 years old (hard copy and digital copies) - from page 152 of 2014 FFIEC BSA Exam Manual (157 of pdf):

The record-retention requirements (e.g., five-year requirement to retain relevant OFAC records; for blocked property, record retention for as long as blocked; once unblocked, records must be maintained for five years).

They are certainly not named in any record retention requirements specific to BSA. When a record is "important," but not subject to any legal record retention requirement, the fallback is "between exams;" i.e. you keep them until your next BSA exam, purge, then repeat.

Thanks both for your comments. Since I expect the next exam to be in July, I think we'll maintain physical records until that point and then be able to rely on electronic records after that.

Announce your plan at that time; i.e. don't ask, tell.

That sounds like the voice of experience Ken.

Thanks again all.