ABSTRACT
The record-keeping requirements in respect of customer due diligence (CDD) evidence and transactional records are contained in Regulation 19 while the FSA rules cover other aspects. Under the Money Laundering Regulations 2007 it is permissible to have CDD undertaken by a third party provided that this party are themselves subject to the Regulations or equivalent legal requirements. The Financial Services Authority also requires that all regulated firms make and retain records of all internal reports to the money laundering reporting officer and external reports to the Serious Organised Crime Agency. There is also a requirement to keep records of all employee awareness and training. These records should show the employee’s name, the date, the training given and the results of any test. To achieve all these various requirements, the firm must have a document retention policy.
