Records required by the EAR must be retained for five years from the latest which events?

Records required by the EAR must be retained for five years from the latest which events?

• A. Export
• B. Known reexport, transshipment or diversion
• C. Any termination of the transaction
• D. The latest export, reexport, transshipment, diversion, or termination

Answer: (D)

The timing rule being tested is when the five-year recordkeeping period begins under the EAR. Records must be kept for five years from the date of the latest action that completes or ends the transaction. That means you start the clock from the most recent event among export, reexport, transshipment, diversion, or termination. This ensures the record covers the entire lifecycle of the transaction, including any later actions that could affect its control status. For example, if you export today but a later reexport or diversion occurs, the five-year period starts from that latest action, not from the initial export. If the transaction is later terminated, the clock starts from that termination date. So the correct approach is to measure five years from the date of the latest of those events, rather than from any single earlier action.

The timing rule being tested is when the five-year recordkeeping period begins under the EAR. Records must be kept for five years from the date of the latest action that completes or ends the transaction. That means you start the clock from the most recent event among export, reexport, transshipment, diversion, or termination.

This ensures the record covers the entire lifecycle of the transaction, including any later actions that could affect its control status. For example, if you export today but a later reexport or diversion occurs, the five-year period starts from that latest action, not from the initial export. If the transaction is later terminated, the clock starts from that termination date.

So the correct approach is to measure five years from the date of the latest of those events, rather than from any single earlier action.