A method and system for tracking and providing an audit trail for off-line smart card transactions includes storing information representing a monetary transaction in a permanent memo on an smart card microprocessor and holding the transaction amount in escrow until the stored information is transmitted from the smart card, for example, at an on-line terminal, to a host on-line system for logging to a tracking system. The monetary transaction includes a transaction with an off-line device, such as another smart card. The escrowed transaction amount represents, for example, a load transaction to one of the smart cards and an unload transaction to other smart card. Once the memo is deleted from the respective smart cards, the load values of the respective smart cards are incremented or decremented by the transaction amount. Alternatively, the smart cards may be provided with a card-to-card key, in which case, a permanent memo is stored only on the receiving smart card.