9.2.1 Transactions
Effective from 13/7/2023(AML-CFT Law Articles 16.1(f); AML-CFT Decision Articles 24.1-3, 28.1-2, 29.4)
FIs are obliged to retain the operational and statistical records, documents and information concerning all transactions executed or processed by the FI, whether domestic or international in nature, and irrespective of the type of customer and whether or not a Business Relationship is maintained, for a minimum period of five (5) years. Some examples of the type of records, documents and information which must be retained include but are not limited to:
| • | Customer credit or debit advices, and transaction orders or applications (including those for cash deposits or withdrawals, currency exchange transactions); |
| • | Credit-related documentation, including loan or guarantee applications, agreements, amendments and supporting documents, disbursement or repayment records, collateral pledges, letter of credit documentation, promissory notes; |
| • | Deal tickets, trade blotters and ledgers, settlement and dividend payment records related to foreign exchange, securities dealing or investing transactions; |
| • | Escrow or fiduciary account transaction records; |
| • | Insurance policy premiums, pay-outs, and related transaction records and documents; |
| • | Money transfer records, including book transfers orders, and domestic and cross-border wire transfer orders, and their related originator and beneficiary records; |
| • | Statistics and analytical data related to customers’ financial transactions, including their monetary values, volumes, currencies, interest rates, and other information. |
In addition to the above, FIs should compile notes on any particularly large or unusual transactions, and keep these notes as part of their records. In particular, FIs licensed by the Central Bank must examine the background and purpose of all complex, unusual large transactions and all unusual patterns of transactions, which have no apparent economic or lawful purpose, and document their findings in writing. This includes transactions that are not considered necessary to be reported as suspicious. These findings must be maintained for inspection by the Central Bank for a period of at least five years.