Treasury Demands You Stash Sanctions Papers for 10 Long Years Now!
Published Date: 3/21/2025
Rule
Summary
The Treasury’s Office of Foreign Assets Control (OFAC) is making a big change: businesses and individuals must now keep certain records for 10 years instead of 5. This matches the longer time allowed to investigate violations of sanctions laws. The new rule kicks in on March 21, 2025, so get ready to hold onto your paperwork twice as long!
Analyzed Economic Effects
2 provisions identified: 0 benefits, 2 costs, 0 mixed.
EU Firms May Face Retention Conflict
Financial institutions subject to European Union anti-money-laundering rules may face difficulties because EU rules (Directive 2015/849, article 40) can require deletion of personal transaction records after 5 years, while OFAC requires 10 years. OFAC notes this potential tension and says it will account for conflict-of-laws issues in enforcement (General Factor K).
Recordkeeping: Keep Sanctions Records 10 Years
If you are a business or individual subject to OFAC recordkeeping rules, you must keep certain records for 10 years instead of 5 years. This change is effective March 21, 2025, and aligns record retention with the extended statute of limitations for violations under the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA).
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Key Dates
Department and Agencies
Related Federal Register Documents
2026-20683, Notice of OFAC Sanctions Actions
The U.S. Treasury’s OFAC just updated its sanctions list on October 5, 2026. Some people had their blocked property unlocked and were removed from the blacklist, while others had their info updated but remain blocked. These changes affect who can access money or property under U.S. rules, so watch for the latest details if you’re involved.
2026-20526, Notice of OFAC Sanctions Actions
The U.S. Treasury’s OFAC just updated its sanctions lists by unblocking some people and removing their names from the banned list. They also cleaned up duplicate entries and updated info on others who remain blocked. These changes affect individuals and entities tied to sanctions, with some unblocked as of July 27, 2026, meaning their assets are no longer frozen.
2026-20525, Notice of OFAC Sanctions Action
The U.S. Treasury’s OFAC just blocked the property of Faouzi Barika and others linked to Hamas, making it illegal for Americans to do business with them. This action, effective October 2, 2026, freezes their assets under U.S. law to stop support for terrorism. If you’re a U.S. person, watch out—any dealings with these folks are off-limits and could have serious consequences.
2026-20475, Notice of OFAC Sanctions Action
On October 1, 2026, the U.S. Treasury’s OFAC added new individuals and companies to its blacklist, freezing their U.S.-based assets. This means Americans can’t do business with these blocked parties, cutting off their access to U.S. money and markets. The move aims to tighten financial controls and protect U.S. interests.
2026-20425, Notice of OFAC Sanctions Action
The U.S. Treasury’s OFAC just blocked the property of Rafael Buenrostro Martin and others for their roles in illegal drug trade and terrorism. From September 29, 2026, Americans can’t do business with these folks, freezing their assets under U.S. law. This move aims to cut off their money flow and stop bad activities fast and firmly.
2026-20395, Notice of OFAC Sanctions Action
The U.S. Treasury’s OFAC just blocked all property linked to A7 NETWORK, a criminal group operating in Russia, Kyrgyzstan, Nigeria, and Zimbabwe. This means Americans can’t do business with them anymore, effective October 1, 2026. It’s a big move to stop shady international crime and protect U.S. interests.
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