AML 4 MSB 12. Record Keeping
Record Keeping is an essential part of most businesses already.
However - just in case:
From the guidance:
7.1 You must retain:
- copies of the evidence obtained to satisfy customer due diligence obligations and details of customer transactions for at least five years after the end of the business relationship
– details of occasional transactions for at least five years from the date of the transaction– details of actions taken in respect of internal and external suspicion reports– details of information considered by the nominated officer in respect of an internal report, where the nominated officer does not make a suspicious activity report– copies of the evidence obtained if you are relied on by another person to carry out customer due diligence, for five years from the date that the third party’s relationship with the customer ends, the agreement should be in writing
7.2 You must also maintain a written record of:
- your risk assessment and any changes made
- your policies, controls, and procedures and any changes made
- what you have done to make staff aware of the money laundering and terrorist financing legislation and related data protection requirements, as well as the training given to staff
You can maintain your records in hard copy or electronically - however, your systems should be appropriate to the size and scope of your business.
If you are using electronic storage - and let’s face it, who isn’t? Then you are obliged to maintain regular and routine backup with off-site storage.
Records are the things that turn up in court. At the risk of getting dramatic on you - records are your sword and shield. Handy things to have in a fight.
In the eyes of the law, then if you haven't recorded it, you haven't done it. Every policy or procedure document that Lime prepares includes a “Document Review Record”. A simple page that records what date the document was reviewed or amended, by whom, for what reason. Sometimes, we review a policy, and there is nothing to change. We type the date, initials and “Annual Review - no changes.” It’s as simple as that. You would surprised how many Firms neglect to do it. During an audit, or worse, a court case, you do not want to be presented with a policy document from your own firm dated ten years ago, with no evidence that it has ever been looked at since.
Lime can help you with your record keeping - and even your back up strategy. Get in touch.