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Prevention of money laundering and the financing of terrorism

Record keeping 

General legal and regulatory requirements

7.1 This chapter provides guidance on appropriate record keeping procedures required by the Regulations. The purpose of the record keeping requirement is to ensure that there is an audit trail that could assist in any financial investigation by a law enforcement body. These records are also important when the Commission is conducting an investigation for compliance purposes. 

7.2 The casino operator’s record keeping policy and procedure should cover records in the following areas:

  • details of how compliance has been monitored by the nominated officer
  • delegation of AML/CTF tasks by the nominated officer
  • nominated officer reports to senior management
  • information or other material concerning possible money laundering or terrorist financing not acted upon by the nominated officer, with reasoning why no further action was taken
  • customer identification and verification information
  • supporting records in respect of business relationships
  • employee training records
  • internal and external SARs, including decisions and actions taken by the nominated officer
  • contact between the nominated officer and law enforcement or the NCA, including records connected to requests for a defence (appropriate consent).

7.3 The policy and procedure for record-keeping should also make provision for the retention of records held by an employee who leaves the business. 

7.4 The record keeping requirements for supporting records, that is, the records of ongoing transactions with a customer, are based on the nature of the relationship with that customer. There is either:

  • no relationship, or
  • a 'business relationship', depending on the circumstances.

Next chapter: Business relationships