ML Sch 1 Record keeping requirements

The aim of the guidance in the following table is to give the reader a quick over-all view of the relevant record keeping requirements.

It is not a complete statement of those requirements and should not be relied on as if it were.

ML 7.3.2 R (1)(a)

Customer identification

Full details of evidence of identity

As soon as reasonably practicable after first contact

5 years from end of relationship with client

ML 7.3.2 R (1)(b)

Transactions

Full details

On effecting the transaction

5 years from the date when the transaction was completed

ML 7.3.2 R (1)(d)

Internal and external reporting

Full details of actions taken

Once actions have been taken

5 years from the creation of the record

ML 7.3.2 R (1)(e)

Information not acted upon

Full details of information considered by the MLRO but not made an external report

Once decision not to report has been made

5 years from the obtaining of the information