Retention of OFAC and 314a Records

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Question:

We've never had a match on OFAC or FinCen. We've had close ones but never an exact match. What is the record retention requirement for those reports that we've printed and reviewed to check the possible matches?

Answer:

314(a) lists are very confidential. If you keep the lists themselves, keep them secured. But you could reference the list by issuance and clearly indicate they were reviewed. Keep them at a minimum from exam to exam to show that you checked your records as required. Most of BSA retention is for 5 years and many banks have opted to include the 314(a) verifications in this retention pool.

First published on BankersOnline.com 12/6/04