A financial institution must carry out a paper record search to the extent that the information on residence of an Account Holder is not captured by the electronic search.
For example, where the electronically searchable databases contain all the required information except for details of standing instructions to transfer funds, the paper record search will only be required to look for that information.
The paper record search should include a review of the current master file and, to the extent that they are not contained in the current master file, the following documents associated with the account and obtained by the financial institution within the last five years.
These should be reviewed for any of the indicia of residence detailed in AEIM 102920.
A financial institution can rely on the review of High Value Accounts by third party service providers where there is a contract obliging the service provider to perform the review.