AML Consultants
Money Laundering
Terrorism Financing
Codes from Regulators
Guidance from Regulators
Economic Sanctions
Risk Based Approach
AML CFT Risk Assessment
AML CFT Programme
Ongoing Due Diligence
Reporting Suspicious Transactions
Staff Vetting
Training
Record Keeping
Third Party Agents
Policies & Procedures
Designated Business Groups
Typologies - Red Flags
About AML Consultants
Contact
   
 


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 appropriate 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. 

An example of 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.  A poor practice would include insufficient verbal interaction with the customer, obtaining verification records from the customer without independent checking 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.