Article 46-2 of Japan's Financial Instruments and Exchange Act (FIEA) requires a financial instruments business operator that conducts Type I financial instruments business to create and retain books and records of its business as a Cabinet Office Order provides. For the records of a US swap dealer, 17 CFR 1.31 sets the retention period and method. MiFID II requires, in Article 16(6) and (7), records of transactions and of telephone and electronic communications.

Record keeping is a separate duty from reporting transaction details to authorities or trade repositories. The article on record keeping covers the records covered and the periods in each jurisdiction.