04.06 – Retention of Documentary Evidence

A Financial Institution or a third party undertaking due diligence procedures for a Financial Institution must retain records of the documentary evidence, or notation or record of the documents reviewed and used to support an account holder’s status for six years following the end of the year in which the status was established.

The documentary evidence can be retained as originals, photocopies or in an electronic format.
A Financial Institution that is not required to retain copies of documentation reviewed under AML due diligence procedures will be treated, for the purposes of the Agreement, as having retained a record of such documentation if it retains a record in its files noting:

  • the date the documentation was reviewed,
  • each type of document,
  • the document’s identification number where present (for example, a passport number), and
  • whether any US indicia were identified.

For High Value Pre-existing Accounts where a Relationship Manager enquiry is required, records of electronic searches, requests made and responses to Relationship Manager enquiries should also be retained for six years following the end of the year in which the due diligence was undertaken. Guidance on the identification and role of a Relationship Manager can be found at 5.17.