AML: Record Keeping, Training and Awareness Flashcards
What items should be put in training records relating to MLTF?
What training was provided and when
Under the MLTF and Transfer of Funds 2017 regulations, which records must be kept for 5 years?
CDD records
Does proof of compliance with requirements for money laundering training need to be kept for 5 years?
No
Who is likely to face prosecution if an employee has not received money laundering training and fails to disclose an incident?
Their employer
How long as a minimum should a tax adviser keep records relating to CDD to comply with MLTF and Transfer of Funds Regulations 2017?
A compulsory 5 years from the end of the client relationship
What is the minimum retention period for records relating to suspicious activity reports sent to the NCA?
A recommended 5 years
You outsource AML training to another firm, what should you consider in relation to the retention of training records for staff?
Obtaining and storing copies of the outsourced company’s training records
Whether the outsourced company’s record keeping procedures are good enough
How soon must a new relevant employee receive training according to the guidance in AMLGAS?
Promptly
How should records relating to SARs be stored?
Separately and securely from working papers to avoid tipping off
What is the maximum time period that AMLGAS recommends a business to keep records containing a client’s personal data?
10 years after the end of the business relationship
Who should be provided with AML training?
Employees who are partners
Relevant employees
Any employees that the business considers should receive MLTF training
What should be included in AML training?
Red flags highlighting potentially suspicious activities
Data protection requirements
The law within the context of the business’s own commercial activities
