(Guideline Chapter 9)

Record-keeping is an essential part of the audit trail for the detection, investigation and confiscation of criminal or terrorist property or funds. Record-keeping helps investigating authorities to establish the financial profile of a suspect, trace the criminal’s or terrorist’s property or funds and assists the court to examine all relevant past transactions to assess whether the property or funds are the proceeds of or relate to criminal offences or terrorist activities.

record keeping

How long must GRDA keep the record ?

For each customer :

  • Throughout the continuance of the business relationship with the customer and for a period of at least 5 years after the end of the business relationship.

For each transaction :

  • At least 5 years after the completion of a transaction regardless of  whether the business relationship ends during the period.

What record must GRDA keep for each customer?

The original or a copy of the documents , and a record of the data and information obtained in the course of identifying and verifying the identity of :

  • the customer;
  • beneficial owner of the customer;
  • the person who purports to act on behalf of the customer; and
  • other connected parties that are relevant person to the customer.

 

The original or a copy of the documents, and a record of the data and information, on the purpose and intended nature of the business relationship.

 

The original or a copy of the files relating to the customer’s business relationship and business correspondence with the customer and any beneficial owner of the customer.

What record must GRDA keep for each transaction?

The original or a copy of the documents, and a record of the data and information obtained in connection with the transaction, including the following types of information:

  • the identity of the parties to the transaction;
  • the nature and date of the transaction;
  • the type and amount of currency involved;
  • the origin of the funds (if known);
  • the form in which the funds were offered or withdrawn, e.g. cash, cheques, etc;
  • the destination of the funds;
  • the form of instruction and authority; and
  • the type and identifying number of any account involved in the transaction (where applicable).

How will GRDA keep the record

If the record consists of a document, either the original of the document should be retained or a copy of the document should be kept on microfilm or in the database of a computer. If the record consists of data or information, such record should be kept either on microfilm or in the database of a computer.