Which records must you keep?
Three groups: AML/CTF program records, customer due diligence records and transaction records for the designated service. AUSTRAC says they must be reasonably necessary to show you are meeting your obligations and sufficient to reconstruct individual transactions.
Records can be paper or electronic, but they must be accurate and complete.
Remember
- Program records, CDD records, transaction records.
- Enough to reconstruct what happened.
Facts and sources for this part
- AUSTRAC: the records you must keep are AML/CTF program records, customer due diligence (CDD) records and transaction records related to a designated service. [S14]
- AUSTRAC: records must be "reasonably necessary to show you’re meeting your CDD and AML/CTF program obligations" and "sufficient to reconstruct individual transactions". [S14]
How long do you keep them?
AUSTRAC says records are kept for a specific period, usually 7 years. Check your own program for the exact periods that apply to each record type.
Do not delete a customer’s file because the job finished. The clock starts later than that.
Remember
- Usually 7 years.
- Closing the job is not the end of the duty.
Facts and sources for this part
- AUSTRAC: records are kept "for a specific period, usually 7 years". [S14]
What counts as a record?
More than forms. AUSTRAC’s list includes emails and other correspondence, senior manager approvals, reports, transaction details and meeting minutes.
For CDD you must also record how you established each matter on reasonable grounds. A copy of an ID is not the whole record.
Remember
- Emails and approvals can be records.
- Record how you decided, not just what you collected.
When is a cash report needed?
If you provide a designated service involving the transfer of $10,000 or more in physical currency, you must submit a threshold transaction report to AUSTRAC. The same threshold applies to foreign currency of the same value.
This is separate from a suspicious matter report. A cash report does not need suspicion.
Remember
- $10,000 or more in physical currency means a TTR.
- It covers receiving and paying cash.
Why do training records matter?
AUSTRAC expects you to keep records reasonably necessary to show you trained your people, and suggests recording who was trained, what they were taught and how understanding was assessed.
A register that shows completion dates and when more training is due is how a small business shows this without a mountain of paper.
Remember
- Keep a training register.
- Record who, what, when and how it was checked.
Facts and sources for this part
- AUSTRAC: "You must keep records that are reasonably necessary to demonstrate compliance with your personnel training obligations." [S1]
- AUSTRAC examples of training records: who completed training (names, roles, teams), what was delivered (topics, format, content version) and how understanding was assessed. [S1]
- AUSTRAC: "Maintaining a training log or register can help make sure that" all relevant personnel have been trained, you can identify who needs refresher training and you can demonstrate compliance to AUSTRAC. [S1]
Check what you have learned
Three questions from the test, each explained. Tap an answer.
Question 1 of 3
Does the cash threshold apply to foreign currency?
Show the answer
Right answer: B, Yes, to foreign currency of the same value. AUSTRAC says the $10,000 threshold applies to foreign currency of the same value. [S13]
Question 2 of 3
Records must be sufficient to do what?
Show the answer
Right answer: A, Reconstruct individual transactions. AUSTRAC says records must be sufficient to reconstruct individual transactions. [S14]
Question 3 of 3
Which of these does AUSTRAC suggest recording about training?
Show the answer
Right answer: D, Who completed it, what was delivered and how understanding was assessed. AUSTRAC’s examples are who completed training, what training was delivered and how understanding was assessed. [S1]