AML Record Keeping

What Records Should Companies Keep?

The types of records that need to be collected can be summarized as follows:

• Customer Information: This includes records of customer identification such as name, address, date of birth, and other identifying information required by local regulations. Companies must verify customer identity before doing business with them and keep records of the verification process.

• Transactions: Companies should keep records of all transactions with their customers, including the type and amount of the transaction, the date, and the parties involved.

• Compliance Officer/MLRO Annual Reports: The Compliance Officer/MLRO (Money Laundering Reporting Officer) is responsible for ensuring that the company is complying with local AML regulations. Companies should keep records of the MLRO's annual reports, which summarize the firm's AML activities.

• External and Internal Suspicion Reports: Companies are required to report any suspicious activities to local regulatory authorities. They should keep records of these reports and the actions taken in response to them.

• Investigation Records: If an investigation is conducted into suspicious activities, companies should keep records of the investigation, including any evidence collected.

• Information that is not Processed: Companies should keep records of any information they receive that is not processed, such as customer requests for information or complaints.

• Actions taken as a result of Agency Requests: If a regulatory authority requests information from a company, the company should keep records of the information provided and any actions taken as a result.

• Training and Compliance Monitoring: Companies should keep records of employee training and compliance monitoring activities to ensure that employees are trained in AML regulations and are following company policies.

• Information about the Effectiveness of Training: Companies should keep records of the effectiveness of their training programs, such as employee test scores and feedback, to improve future training efforts.