OFAC’s shift to data-driven enforcement is turning sanctions reporting and recordkeeping into core compliance risks. Mandatory electronic filing and a 10-year retention rule give regulators more data to compare, test, and mine for enforcement leads. Screening alone is no longer enough: companies must be able to show, through complete and retrievable records, how sanctions decisions were made, escalated, reported, and retained. Gaps once treated as administrative now can point to weak controls, poor governance, and broader sanctions exposure.
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