Leela
AML Program
AP-09

Retain program records for five years

Requirement

Copies of this policy, every supporting procedure, the officer designation and the bank’s acknowledgment, training records, independent test reports and remediation logs, quality assurance reports, and board compliance reports and minutes are retained for at least five years in a format accessible for sponsor bank review and regulatory examination.

Trigger

Continuous

Five years from the date of each record

Action

File each program record under the retention schedule with its date, keep superseded versions, and be able to produce any record on request.

Evidence
  • Retention schedule entry

    Record class, retention period, location

  • Program document archive

    Every version of the policy and procedures with its dates

Owner

AML Compliance Officer

Leela can
Monitor

Leela can watch for the trigger, keep the clock, and flag what is late.

Leela can hold each program record with its date and prove retention when the bank or an examiner asks.

Applies

Tell Leela about your company to see whether this applies.

Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

What’s next?