For every transaction sufficient records must
be kept to enable the transaction to be readily reconstructed and at a minimum
the records must contain information on the -
Nature of transaction;
Value;
Currency;
Parties involved;
Accounts involved;
Name of the employee or agent who had face-to-face dealings with the parties involved.
Transaction records must be kept for a period of at least 5 years, commencing from when the transaction was completed.
Identity and verification records
When a customer provides
an original document, it is best practice to take a copy of the document’s
image, as opposed to recording only some of the identity information. Taking
an image copy of the identity section of a passport or drivers licence will
provide all available data and lessen the risk of human error when transferring
the information onto another medium.
When staff
are undertaking identification and verification they need to be alert to any
anomalies such as use of falsified records, mismatching of information between
records, or detail in the records not matching what the customer has verbally provided.
Best
practice is to ask the customer their full details, make a record of the
details provided and then confirm those details by referring to the documents
that provide independent verification.
Poor
practice would include insufficient verbal interaction with the customer, asking
for verification records at the outset and directly recording the customer’s
information on to a database or customer form.
Other records The
Act requires the retention of other record types including –
Records that are relevant to the
establishment of the business relationship;
Records relating to risk
assessments, AML CFT programmes and audits;
Any other records obtained during
the course of the business relationship that assist to understand the
nature and purpose of the relationship, and activities relating to the relationship. These records are required to be kept for a period of at least 5 years after the relationship ends.
