The Presidential Records Act doesn't contain explicit penalties for violations, and violating the P.R.A. may or may not constitute obstruction of justice, but the P.R.A. may be covered by some provisions of the Sarbanes-Oxley Act, in which case the Sarbanes-Oxley penalties may be applicable. Sarbanes-Oxley applies to record-keeping requirements, whether or not any "official proceeding" is active or pending.

http://www.usdoj.gov/ag/readingroom/sarox1.htm

Field Guidance on New Criminal Authorities Enacted in the Sarbanes-Oxley Act of 2002 (H.R. 3763) Concerning Corporate Fraud and Accountability

Section 802. Criminal Penalties for Altering Documents

Previous law: . . . While prosecution of obstruction under 18 U.S.C. § 1505 does not require "corrupt persuasion," it does require the existence of a pending proceeding . . .

Amendment: Section 802 adds two new criminal provisions, 18 U.S.C. §§ 1519 and 1520. Section 1519 expands existing law to cover the alteration, destruction or falsification of records, documents or tangible objects, by any person, with intent to impede, obstruct or influence, the investigation or proper administration of any "matters" within the jurisdiction of any department or agency of the United States, or any bankruptcy proceeding, or in relation to or contemplation of any such matter or proceeding. This section explicitly reaches activities by an individual "in relation to or contemplation of" any matters. No corrupt persuasion is required. New Section 1519 should be read in conjunction with the amendment to 18 U.S.C. 1512 added by Section 1102 of this Act, discussed below, which similarly bars corrupt acts to destroy, alter, mutilate or conceal evidence, in contemplation of an "official proceeding." . . .

New 18 U.S.C. § 1519 provides: Whoever knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States or any case filed under title 11, or in relation to or contemplation of any such matter or case, shall be fined under this title, imprisoned not more than 20 years, or both.

Sec. 1102. Tampering with a Record or Otherwise Impeding an Official Proceeding.

Previous Law: Title 18 U.S.C. § 1512, in part, provides a 10 year maximum term of incarceration for an offender who corruptly persuades another person with the intent to, in part, destroy or alter evidence.

Amendment: The amendment adds new subsection (c) to Section 1512 and renumbers existing subsections (c) through (i) as (d) through (j). New subsection (c) imposes a fine and/or a term of imprisonment of up to 20 years on any person who corruptly alters, destroys, mutilates or conceals a record, document or other object with the intent to impair the object's integrity or availability for use in an official proceeding, or who corruptly otherwise obstructs, influences or impedes an official proceeding. Section 1512, as amended, should be read in conjunction with the new Section 1519, added by section 802 of this Act, which criminalizes certain acts intended to impede, obstruct or influence "any matter" within the jurisdiction of any Department or agency of the United States, or in relation to or contemplation of any such matter. The term "corruptly" shall be construed as requiring proof of a criminal state of mind on the part of the defendant.

New Section 1512 (c) provides:
(c) Whoever corruptly-
(1) alters, destroys, mutilates, or conceals a record, document, or other object, or attempts to do so, with the intent to impair the object's integrity or availability for use in an official proceeding; or
(2) otherwise obstructs, influences, or impedes any official proceeding, or attempts to do so, shall be fined under this title or imprisoned not more than 20 years, or both.

I wonder if Fred Fielding has been boning up on Sarbanes-Oxley lately.