Retain onboarding and review records for five years after offboarding

KYC / CIP / KYB policy, §9

All identification records, beneficial ownership certifications, due diligence files, and periodic review records are kept for at least five years from the date of offboarding, in a format accessible for sponsor bank review and examination. The clock runs from offboarding, so a live customer’s file is never purged.

Continuous

Five years from each customer’s offboarding

Store each customer file under the retention schedule, key retention to the offboarding date, and be able to produce any file on request.

• Retention schedule entry

  Record class, retention period keyed to offboarding, location

AML Compliance Officer

Leela can hold each file with its offboarding date and prove retention on request.

Tell Leela about your company to see whether this applies.