Extract to table

• Full Transaction-Party Screening: All parties to a transaction must be screened, not merely the direct counterparty

• Alert Management and Escalation Workflow: All screening hits—whether generated by name matching, beneficial ownership analysis, or adverse media screening—must be reviewed by a qualified member of the compliance function

• Documentation and Audit Trail Requirements: All screening activities, alert dispositions, and escalation decisions must be documented and retained in a centralized compliance records management system

Records must be retained for a minimum of five years, consistent with OFAC recordkeeping requirements (31 C

The program must address the complete lifecycle of export control compliance, from product classification through end-user screening, license determination, and recordkeeping

All records must be retained in a centralized and auditable system for a minimum of five years following the termination of the counterparty relationship