Q&As

How long should I retain records relating to an external suspicious activity report (SAR) to the National Crime Agency (NCA), and is the retention period affected by whether or not the SAR concerned involved a request for consent/a defence?

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Published on LexisPSL on 30/04/2021

The following Practice Compliance Q&A provides comprehensive and up to date legal information covering:

  • How long should I retain records relating to an external suspicious activity report (SAR) to the National Crime Agency (NCA), and is the retention period affected by whether or not the SAR concerned involved a request for consent/a defence?

How long should I retain records relating to an external suspicious activity report (SAR) to the National Crime Agency (NCA), and is the retention period affected by whether or not the SAR concerned involved a request for consent/a defence?

If you are subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, you must establish and maintain appropriate and risk-sensitive policies and procedures relating to record keeping.

Record keeping is an essential component of the anti-money laundering (AML) and counter-terrorist financing regime because it:

  1. evidences your compliance with regulatory obligations, and

  2. assists law enforcement agencies in conducting financial investigations

Record keeping requirements are not subject to the risk-based approach and therefore there is no

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