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Status: You are viewing the version of the handbook as on 2005-06-30.

ML 7.3 Record keeping arrangements

ML 7.3.1G

SYSC 3.2.20 R (Records) requires a relevant firm to take reasonable care to make and retain adequate records (including accounting records). This section amplifies this requirement.

ML 7.3.2R
  1. (1)

    A relevant firm must make and retain, for the periods specified in (2), the following records:

    1. (a)

      in relation to evidence of identity:

      1. (i)

        a copy of the evidence of identity obtained under ML 3; or

      2. (ii)

        a record of where a copy of the evidence of identity can be obtained; or

      3. (iii)

        when it is not reasonably practicable to comply with (i) or (ii), a record of how the details of the evidence of identity can be obtained; and when it has concluded it should treat a client as financially excluded ML 3.1.5 G to ML 3.1.7 G (Financial exclusion), a record of the reasons for doing so;

    2. (b)

      a record containing details of every transaction carried out by the relevant firm with or for the client in the course of regulated activity;

    3. (c)


    4. (d)

      records of action taken under ML 4.1 (Internal reporting) and ML 4.3 (External reporting); and

    5. (e)

      when an MLRO has considered information or other matter concerning knowledge or suspicion that another person has engaged in money laundering, but has not made a report to NCIS under ML 4.3, a record of that information or other matter.

  2. (2)

    The specified periods are:

    1. (a)

      in relation to evidence of identity, five years from the end of the relevant firm's relationship with the client;

    2. (b)

      in relation to transactions within (1)(b), five years from the date when the transaction was completed; and1

    3. (c)


    4. (d)

      in any other case, five years from the obtaining of the information or the creation of the record.

  3. (3)

    "Transaction" in (2) does not include advice given to a client unless such advice is followed by a transaction with monetary value.

ML 7.3.3G

Records kept under SYSC 3.2.20 R should include the dates when anti-money laundering training was given, the nature of the training, and the names of the staff who received training; and (in relation to anti-money laundering monitoring) reports by the MLRO made in accordance with ML 4.3, and records of consideration of those reports and of any action taken as a consequence.