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1Fix the driver behind crashes, sound loss and screen glitches2Clear out junk files and repair common Windows errors3Scan for outdated or missing drivers - takes under a minuteIf you are a U.S. person that files a notification under the U.S. Treasury’s Outbound Investment Security Program (31 CFR Part 850), keep a copy of the filed notification and its supporting documentation for 10 years from the filing date. Treasury can request those materials during that period.
The rule is narrower than a general foreign-investment records policy. It applies to specified transactions involving U.S. persons, covered foreign persons, and defined national-security technologies or products connected to countries of concern. Investors should first confirm that the transaction and parties meet the current Part 850 definitions. For transactions that fall outside the program, other tax, securities, corporate, fiduciary, or contractual rules may create different recordkeeping duties.
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What Part 850 covers
Part 850 is the U.S. Treasury Outbound Investment Security Program. It addresses specified transactions involving a U.S. person, a covered foreign person, and covered national-security technologies or products in countries of concern. It is not a universal retention schedule for every foreign investment, fund commitment, acquisition, or joint venture.
The first record in any compliance file should therefore be the coverage analysis: which transaction category is involved, which parties are relevant, what country-of-concern connection exists, and whether the technology or product falls within the rule. Keep the facts and analysis used to reach that conclusion, even when the conclusion is that no notification is required. The regulation’s express 10-year requirement, however, is tied to a filed notification and its supporting documentation.
The express 10-year retention requirement
Section 850.405(c) requires a U.S. person to maintain a copy of the notification filed and supporting documentation for 10 years from the date of filing. The clock begins on the filing date, not necessarily on signing, closing, or the date the investment was first discussed.
Supporting documentation can include, as applicable:
- Pitch decks and other fundraising or presentation materials
- Marketing letters
- Offering memorandums
- Transaction documents, including side letters and investment agreements
- Transaction-related due-diligence materials
These examples describe the types of evidence Treasury may expect to see; they do not require every investor to create a document in a particular format. A document belongs in the file when it supports the notification, the transaction facts reported in it, or the diligence behind the classification.
What the 10-year rule does and does not mean
The rule clearly covers the filed notification and its supporting documentation. It does not state one universal retention period for every internal policy, training record, email, corporate minute, or investment record that might relate to outbound investing. Those materials may still be important evidence, but their treatment depends on their purpose and the facts of the transaction.
If a diligence memorandum, board paper, ownership chart, or internal approval record supports a filed notification, preserve it with the supporting file. If a general compliance policy is unrelated to a particular filing, Part 850 does not, in the material summarized here, assign that policy a separate fixed period.
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Build the file around the information a notification must contain
A strong transaction file lets another reviewer reconstruct what was known, what was reported, and how the reported figures were calculated. Organize records around the notification’s information categories rather than around whichever documents happen to arrive by email.
| Record group | Examples of records | Part 850 treatment |
|---|---|---|
| Filed notification | Submitted electronic form, final attachments, filing date, and electronic acknowledgment | Retain for 10 years from the filing date |
| Transaction evidence | Investment agreement, side letter, offering memorandum, pitch deck, marketing letter, closing materials | Supporting documentation; retain for 10 years when supporting a filed notification |
| Ownership and organization | Post-transaction organizational charts, intermediate and ultimate parent information, ownership and governance records | Keep as evidence supporting reported structure; a separate period is not stated in Part 850 |
| Diligence and classification | Information requests, public-source reviews, database results, warning-sign analysis, diligence memoranda | Evidence of reasonable-and-diligent inquiry; a separate period is not stated, but relevant material forms part of the supporting file |
| Internal controls | Training, reporting, control reviews, testing, audits, governance or shareholder-rights evidence | Relevant compliance-step evidence in appropriate cases; a separate period is not stated |
| Filing chronology | Dated drafts, updates, Treasury questions and responses, proof of when later information became available | Practical evidence for filing and update deadlines; a separate period is not stated |
Identity, contacts, and ownership
Retain the information used to identify the filing person, the designated contact person, and relevant ownership details. Keep the underlying organizational records that show why those details were reported, such as entity documents, ownership schedules, or approved corporate records.
Post-transaction organizational charts
Save the post-transaction charts for both the U.S. person and the covered foreign person. The charts should identify intermediate and ultimate parent entities and show relevant relationships. Date each version so a reviewer can tell whether it represents the structure before closing, immediately after closing, or after a later reorganization.
Commercial rationale, structure, and timing
Preserve the memorandum or approval record explaining the commercial rationale, the transaction structure and applicable transaction category, the transaction’s status, and its actual or expected completion date. If the expected completion date changes, keep the dated explanation and the updated filing materials rather than overwriting the earlier version.
Value, consideration, and governance rights
The file should support the transaction value and the method used to calculate it. Keep records showing the form of consideration, equity and voting interests, board seats, future investment commitments, and options. Term sheets, cap tables, valuation workpapers, subscription documents, side letters, and governance agreements may each explain a different part of the reported answer.
Covered foreign person and management information
Keep the information used to identify the covered foreign person and relevant officers, directors, and management. Where the information comes from a corporate disclosure, registry extract, diligence response, or other source, retain the source and the date it was obtained.
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Preserve the diligence that existed before the transaction completed. This should show what was asked, who answered, which sources were checked, and how unresolved issues affected the classification or filing decision.
Document a reasonable-and-diligent inquiry
Part 850 does not provide a single checklist that guarantees compliance. It assesses the inquiry from the totality of relevant facts and circumstances. Your records should therefore show the process, not merely a conclusion such as “approved” or “no issue.”
Information sought
Record efforts to obtain relevant nonpublic information from the issuer, target, fund manager, co-investors, advisers, and other parties with direct knowledge. Keep the questions sent, responses received, follow-up requests, and explanations for any unanswered request.
Public information reviewed
Identify the public sources reviewed and preserve copies or stable exports when permitted. The record can include corporate filings, ownership disclosures, government records, published technical descriptions, sanctions or export-control information, and other public material relevant to the transaction.
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Conflicts, gaps, and warning signs
Note where sources agree, conflict, or leave material uncertainty. The regulation specifically points to warning signs such as evasive answers or refusals to provide information. A refusal should not disappear from the file; record what was requested, what was refused, when it happened, and what additional steps were taken.
Use of databases and commercial sources
Record the public or commercial databases consulted, the search terms or entities used where practical, the date of the search, and the result that informed the analysis. If a database is updated later, preserve the original result relied on for the filing as well as any later correction relevant to an update.
Information that was avoided
Document material information that was not pursued and why. Deliberately avoiding relevant information can undermine the credibility of the inquiry. A short explanation of scope, limitations, and escalation decisions is more useful than an undated checklist with no supporting evidence.
Records for controlled foreign entities and internal controls
For a U.S. person with a controlled foreign entity, Part 850 identifies potential compliance steps whose relevance depends on the circumstances. Keep evidence when those steps are part of your control framework:
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- Periodic training materials, attendance records, and internal reporting
- Written internal controls, including approval, escalation, and documentation procedures
- Periodic reviews showing that controls were reassessed as the business or rule changed
- Testing or auditing records, including findings, remediation owners, and completion dates
These records demonstrate reasonable compliance steps; they do not turn into a universal checklist or guarantee that a particular program is sufficient. Tailor the evidence to the entity’s ownership, transaction volume, decision rights, and risk profile.
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Manage the filing calendar and preserve every version
Part 850 creates deadlines that can add records after the initial transaction file is assembled. Required notifications under sections 850.401 or 850.402 generally are due within 30 calendar days after transaction completion. A notice under section 850.403 is generally due within 30 days after acquiring the specified post-transaction knowledge.
If a filing was made before completion and information materially changed, update it within 30 days after completion. When information required for a filing was previously unavailable, provide it within 30 calendar days after it becomes available. Keep evidence of the date the information was obtained so the later deadline can be demonstrated.
- Save the submitted notification exactly as filed, including attachments.
- Save Treasury’s electronic acknowledgment and record the filing date.
- Preserve dated drafts when they explain a material change, correction, or decision.
- Store each update as a new version rather than replacing the earlier filing.
- Keep Treasury questions, responses, and any documents submitted afterward.
- Record the date each previously unavailable fact became available and the date it was reported.
The regulation establishes the filing and update deadlines. The version-control steps above are practical file-management measures that make compliance demonstrable.
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Treasury may request information and documents relating to a transaction or Part 850 compliance. A file that is technically complete but impossible to navigate creates avoidable delay. Use consistent names, dates, and access controls; separate drafts from filed versions; and keep a short index identifying the transaction, filing date, parties, and location of supporting records.
Submissions to Treasury must be in English. Part 850 also addresses confidentiality for nonpublic materials submitted to Treasury. Preserve confidentiality markings and handling instructions, but do not assume that confidentiality eliminates the obligation to produce responsive records when Treasury makes a lawful request.
Common recordkeeping mistakes
- Starting the retention clock at closing: the express period runs 10 years from the filing date.
- Keeping only the final form: without the agreements, diligence, calculations, and charts behind it, the filing may be difficult to verify.
- Deleting unanswered diligence requests: refusals and evasive answers can be relevant to the reasonable-and-diligent inquiry.
- Overwriting organizational charts: retain dated pre- and post-transaction versions.
- Ignoring later information: unavailable information has a further 30-calendar-day reporting deadline after it becomes available.
- Treating internal controls as optional paperwork: for controlled foreign entities, training, reporting, reviews, testing, and governance evidence may help demonstrate reasonable compliance steps.
- Assuming Part 850 covers every foreign investment: confirm the current definitions and consider other legal or contractual retention duties separately.
A practical close-out checklist
Before closing the file, confirm that it contains the coverage analysis, transaction documents, ownership and governance evidence, value calculations, management information, pre-transaction diligence, and the records supporting the reasonable-and-diligent inquiry. After filing, add the electronic acknowledgment, the final submitted version, any updates, Treasury correspondence, and proof of dates for information received later.
Set the destruction date for the notification file at 10 years after the filing date only after checking for litigation holds, audits, contractual obligations, or other applicable rules that require longer preservation. Part 850’s 10-year rule is a floor for the covered notification file, not permission to destroy records that another obligation requires you to keep.
Bottom line for investors
For a covered U.S. person that files under Part 850, retain the notification and supporting documentation for 10 years from filing. The most useful supporting file connects the reported answers to transaction documents, ownership charts, value and governance calculations, management information, and a contemporaneous diligence record showing what was sought, reviewed, and unresolved. Keep the filing chronology and later updates so every deadline can be reconstructed. Because Part 850 is transaction- and fact-specific, verify the current regulation and Treasury filing instructions before relying on this checklist for a particular deal.
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