CH31- Record keeping, training and awareness

Question 1

Record keeping

Answer 1

5 year retention period
Info relating to SARs should be kept separate from client working papers- no specified period of retention
If using 3rd parties, ensure they comply with all rules and can provide access
Under AMLGAS, data should not be kept for >10 years

Question 2

Training records

Answer 2

Legal requirement for all relevant employees
Should include:
-Training that was given, date it was given, which individuals received training and results from any assessments
-Explanation of law within context of business
-Red flags which relevant employees need to look out for
-Processes to apply once have suspicion or knowledge of money laundering
-Data protection requirements

Question 3

Subsequent training

Answer 3

All new staff should be trained promptly
Subsequent updates will depend on variou key factors
Ongoing awareness campaigns recommended