Answer:
Checking the OFAC list is a risk management tool - it is not a legal requirement. As you are not required to do anything specific, there is no record retention requirement regarding checking the list. What you want to be able to show is that you have procedures in place that require you to check the list where appropriate and that you follow those procedures. If you hold blocked funds, there will be filing and record retention requirements.
First published on BankersOnline.com 6/06/05
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