The 2025 OFAC 10-Year Rule: Is Your Document Storage Compliant for the Next Decade?

March 12, 2025 quietly became one of the most important dates in dealership compliance. The Office of Foreign Assets Control (OFAC) doubled the statute of limitations for record-keeping from five to ten years, which means audits in 2035 can reach back to deals you delivered this month. Dealers who already follow the workflows in our state-by-state compliance checklist might adapt quickly, but rooftops running on legacy servers or DMS vendors that purge after seven years are suddenly exposed. This guide explains the rule change, the risks of on-prem storage, and how DealerClick’s Cloud-Native Vault keeps every record immutable, discoverable, and “audit-ready” on demand.

The Problem

• Most servers or third-party DMS archives delete or overwrite records after seven years to keep storage costs down.
• When OFAC examiners show up, they expect instant access to deal jackets, sanction checks, ACH logs, and Red Flags documentation—missing files trigger fines and “willful blindness” allegations.
• Paper or on-premise storage is disaster-prone; hurricanes, fires, or M&A transitions frequently break the custody chain.
• Legal and lender partners now ask for proof of retention policies before funding or acquiring stores.
• Manual exports from legacy systems waste hours and rarely include metadata proving tamper protection.

If you already realized the need for redundancy after reading Why Every Dealership Needs a Backup DMS System, this OFAC update raises the bar again.

What Changed on March 12, 2025

OFAC updated its enforcement manual to align the record-retention statute of limitations with broader federal sanctions timelines. Dealers must retain screening records, deal documents, payment histories, customer communications, and any remediation notes for a rolling ten-year period. The burden isn’t just historical storage; regulators want evidence that records are tamper-proof and immediately retrievable. While the change targets financial institutions, independent and franchise dealers fall under the same obligations when they originate or service loans, collect payments, or accept ACH transactions. Our Dealer Management Software Buyer’s Guide already recommended asking vendors about retention windows—now it’s an absolute requirement.

Why On-Prem and 7-Year Vendors Put You at Risk

Legacy servers were never designed for decade-long retention. Disks fail, backups get overwritten, and disaster recovery plans often ignore off-site redundancy. Even if you keep tapes in a closet, recreating a 2017 ACH file in 2030 is nearly impossible without metadata proving it is unaltered. Dealers in Texas and other high-enforcement states face additional state auditor requests layered on top of OFAC. Any DMS that quietly purges at year seven creates a compliance gap that examiners view as willful neglect. The same risks apply to freestanding “document closets” that rely on manual uploads—files can go missing when employees turnover or rename folders. If you still operate a mix of on-prem and cloud tools, it’s time to consolidate.

Key Benefits of Future-Proof Storage

• Audit-ready exports: Deliver ten years of deal data, sanction checks, and payment trails in a single encrypted package.
• Litigation defense: Immutable logs prove what you knew, when you knew it, and how staff responded to potential matches.
• Stronger lender relationships: Funding partners clear deals faster when they see consistent retention policies.
• M&A readiness: Buyers pay more for stores with compliant, centralized archives because diligence is turnkey.
• Less staff drag: No more all-hands searches across file cabinets, tapes, or dusty servers whenever a regulator asks questions.

Inside DealerClick’s Cloud-Native Vault

DealerClick’s Cloud-Native Vault, built on the same architecture as our Auto Dealer Software suite, automatically stores every document, communication, and audit log in write-once, read-many (WORM) repositories with 10+ year lifecycle policies. Data is encrypted in transit and at rest, replicated across regions, and versioned so you can prove nothing changed after the fact. Compliance admins can build “Audit-Ready” export templates that combine sanction screenings, deal jackets, CRM notes via DealerClick Auto Dealer CRM, and payment histories into one download. Every export includes a cryptographic digest so regulators or buyers can validate authenticity immediately.

Implementation Playbook

1. Inventory your existing archives
   Document which systems hold OFAC-relevant data (DMS, CRM, payment gateway, eSignature) and note their retention policies. Compare your findings against the controls outlined in our Cloud-Based Auto Dealer Software guide.

2. Migrate critical records into the Vault
   Use DealerClick migration utilities or APIs to move historical PDFs, scanned documents, and CSV exports into the Cloud-Native Vault. Tag them by rooftop, funding source, and deal number so cross-referencing is instant.

3. Automate retention policies
   Configure lifecycle rules to retain OFAC documents for at least 11 years (ten-year requirement plus a buffer). Lock down deletion rights and enforce legal holds for ongoing investigations or litigation.

4. Build Audit-Ready export packs
   Create templates that pull everything an examiner will request: sanction results, customer communications, ACH logs, and Red Flags notes. Schedule quarterly “dry runs” so you know exports run in minutes, not hours.

5. Train and test the team
   Partner with DealerClick Dealership Training Services to run tabletop exercises. Simulate an OFAC request, assign owners to gather exports, and confirm staff knows how to escalate potential matches.

Conclusion

The 2025 OFAC update is a wake-up call for any dealer relying on on-premise servers or vendors with arbitrary purge policies. Long-term retention is now the price of admission for funding partners, regulators, and acquirers. DealerClick’s Cloud-Native Vault gives you immutable archives, instant exports, and the confidence to prove compliance through 2035 and beyond. If you are ready to see the system in action, our compliance team can walk you through a tailored deployment for every rooftop.

Frequently Asked Questions

Does OFAC accept records stored in third-party clouds?

Yes, as long as you can prove integrity, access controls, and audit logging. DealerClick’s Cloud-Native Vault maintains WORM storage, redundant backups, and detailed access logs so you can document who viewed or exported each file.

How can I prove documents weren’t altered over ten years?

Every file stored in DealerClick receives a unique checksum and timestamp. When you generate an “Audit-Ready” export, the system includes a manifest with those checksums plus user activity logs, giving regulators cryptographic proof that nothing changed.

What about non-OFAC documents like state disclosures or lender stipulations?

Store them in the same Vault. The OFAC rule may have prompted your review, but lenders and state regulators expect identical retention discipline. Centralizing everything alongside workflows in the DealerClick Auto Dealer CRM keeps you ready for any audit.