Recordkeeping and document retention
Recordkeeping obligations in Trade and Geopolitical Risk have tightened considerably, driven in part by enforcement postures at the U.S. Department of the Treasury's Office of Foreign Assets Control and the U.S. Bureau of Industry and Security, both of which have made document retention a live audit issue in sanctions and export control investigations. The European Commission's Foreign Subsidies Regulation has added a parallel documentation layer for M&A and procurement filings, requiring firms to retain records that substantiate subsidy declarations for years beyond transaction close. Compliance teams operating across these jurisdictions are not treating this as a back-office task; they are building retention schedules that map directly to transaction type, counterparty geography, and applicable control regime.
Watch
- BIS recordkeeping rules under EAR Part 762: five-year retention clock and what triggers it
- OFAC's documentation expectations during civil penalty investigations, per its 2023 enforcement guidance
- Foreign Subsidies Regulation Article 28 record retention obligations for notified transactions
- Whether your vendor contracts capture the chain-of-custody records BIS expects on re-exports
- Asia-Pacific export control regimes in Japan and Australia tightening their own audit trail requirements
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to recordkeeping and document retention will appear here as they are published.