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9.2.5 Ongoing Monitoring of Business Relationships

Effective from 13/7/2023

(AML-CFT Law Article 16.1(b),(f); AML-CFT Decision Article 24.2-4)

FIs are required to retain all customer records and documents obtained through the ongoing monitoring of Business Relationships. Examples of such records include but are not limited to:

Transaction review, analysis, and investigation files, with their related correspondence;
 
Customer correspondence (including email and fax correspondence), call reports or meeting minutes (including where applicable recordings, transcripts or logs of telephone or videophone calls) related to those transactions or their analysis and investigation;
 
CDD records, documents, profiles or information gathered in the course of reviewing, analysing or investigating transactions, as well as transaction-related supporting documentation, including the results of background searches on customers, Beneficial Owners, beneficiaries, controlling persons, or counterparties to transactions;
 
Transaction handling decisions, including approval or rejection records, together with related analysis and correspondence.