31 CFR 501.601: every person engaging in any transaction subject to OFAC's regulations must keep a full and accurate record of each transaction, whether licensed or not, available for examination for at least 10 years after the transaction; holders of blocked property (or retained funds) keep a full record of it for as long as it is blocked and at least 10 years after unblocking. The period rose from 5 to 10 years by the rule of 13 September 2024 (89 FR 74834), effective 12 March 2025, following the extension of the IEEPA and TWEA statute of limitations to 10 years by the 21st Century Peace through Strength Act (24 April 2024).
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.