How to retain and securely transfer AML evidence

What belongs in the records

Section 16 includes identifiers, copies made, first-identification details, due-diligence evidence, actions and difficulties, and risk assessment. A declaration or final PDF without sources may not evidence the entire process. Check that exports include history, attachments and human reasoning for the checks actually performed.

Do not create unnecessary document copies just to enlarge the file. Where copies were made or required by the method, keep them readable and secure. Records should remain evidential after staffing changes: who performed what and when, what was verified and how conflicts were resolved.

Duration and trigger are separate fields

The general Section 16(1) and (2) branch requires ten years after a one-off transaction or relationship termination. For paragraphs 1–3, paragraph 5 starts the period on the first day of the month following the last known transaction action. Case creation is not the automatic ten-year trigger for an ongoing relationship. Evidence the relevant event and calculation rule.

The special Section 16(4) branch for Section 2(1)(i) and (j) distinguishes value: ten years after transaction or relationship termination at EUR 10,000 or more, otherwise five years after transaction termination. Do not apply it to office providers or every profession. Training records use another period. Define any additional retention basis, purpose, duration and scope separately.

Transfer and service termination

Use controlled access, secure transfer and recipient verification. Do not expose passwords or permissions through an uncontrolled public link. Before temporary-space deletion, confirm export completeness and archive retrieval. Set backups and recovery with access controls. Shorter product retention does not change statutory duties; long vendor storage without contractual safeguards does not itself satisfy them.

Checking an export before deletion

Choose a file and open it outside the original application. Documents, check times, sources, conclusions and attachment links must be recognisable. Verify readability and association with the correct client. If the format needs a special tool, ensure access after subscription ends. Record receipt checks, document count or inventory and identified gaps. Only then confirm safe takeover into the subsequent archive.

The archive need not be available to every worker, but must enable timely lawful cooperation. Assign file retrieval, recipient verification and secure evidence transfer. Backup recovery must not indiscriminately restore lawfully deleted data into ordinary operation. Link deletion to retention records and copy management. Moving systems creates neither a new basis for unlimited storage nor a new use of the data.