Record Retention

Relevant Law/ Regulation: Money Laundering Regulations (19(3), 20(4) and 45(1)

A firm must keep the following records:

  • Customer Information
  • Details of all financial transactions
  • Internal and external suspicious reports (including information that has not been acted upon)
  • Money Laundering Reporting Officer’s Annual (and other) reports
  • Policies and procedures
  • Training material and records
  • Risk-Based Approach methodology
  • Where the record keeping obligations are not observed, your firm or individuals could be subject to civil and criminal penalties
  • Records must be held for a period of 5 years after the business relationship transaction or the last transaction
  •  In the event of a criminal or regulatory investigation, data to assist in the investigation may be retained for and extended period after the cessation of the business relationship or last transaction