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Record keeping is integral to the success of your business maintaining compliance. Record keeping provides an assurance that your risk treatment process of identifying, mitigating and managing the risk that your designated services may (inadvertantly or otherwise) involve or facilitate ML/TF, is effective.
A range of legislative obligations specify record-keeping requirements regarding your AML/CTF program. These include keeping a record of:
- any records made relating to the provision of a designated service must be retained for 7 years after the record is made
- any documents given to a reporting entity by the customer relating to provision of a designated serice must be kept for 7 years
- any documents a customer provides a reporting entity related to the provision of a designated service, for 7 years after the relationship between your business and the customer ceases
- a copy of the AML/CTF program, variations to the program and a record of the adoption of the program for 7 years after the day the program ceases.
Your business must decide on how best to manage its records. The following actions are suggestions for setting up a data collection/reporting process that forms part of records management:
- set up a system for collecting and reporting data
- write clear definitions of what constitutes data
- agree on a method and measures for establishing data collection performance (if not already determined)
- list resources required to support the design of data collection processes
- agree on data formats and classifications for aggregation and consolidation
- identify possible sources of records management benchmark data, for example Australian Standards, or professional bodies
- set a reporting calendar
- establish data collection and records management roles and responsibilities
- detail training requirements
- validate with process stakeholders.
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