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FAQs - Data Collection & Record Keeping
What client data do I need to collect?
You should collect data that lets you identify the client (for example full name, date of birth or address for individuals; company name, registration number for non-individuals) and understand their ownership/structure (for companies/trusts, who the beneficial owners are).
You should also collect information about the service relation (what service you’ll provide, the nature and purpose of the relationship) so that you can assess the risk.
What is Beneficial Ownership information?
“Beneficial owner(s)” means the real person(s) who ultimately own or control a client that is not an individual (for example a company, trust or other entity).
You need to collect enough information to know who those people are (or if they cannot be identified, an alternative control person) and verify their identity reasonably.
How long do I need to keep AML/CTF records?
You must keep customer identification and verification records for seven years after you have stopped providing any designated service to that client.
You must also keep records of your AML/CTF program (including the program itself, changes, approvals) for seven years after you stop using that program.
There are other records that need to be kept, and you can read the full details HERE.
Can I store client documents digitally?
Yes. What matters is that you store the records securely and in a way you can retrieve them when required. The regime does not force you to keep paper only, digital storage is acceptable provided confidentiality, integrity and accessibility are maintained.
What is transaction monitoring?
Transaction monitoring means having processes in place (manual or automated) to monitor clients’ transactions and other behaviour so that you can identify patterns, large or unexpected movements, or things inconsistent with the client’s profile, and take action if needed.
It is a key part of your AML/CTF program and helps you meet obligations around ongoing due diligence and reporting.
What is suspicious matter reporting (SMR)?
An SMR is a report you must submit to AUSTRAC if you have reasonable grounds to suspect that a customer, transaction or proposed transaction is linked to money-laundering, terrorism-financing, proceeds of crime, tax evasion or a related offence.
It’s not only when you know something is criminal, it’s when you reasonably suspect it based on the information you have.
SMR also needs to be submitted when a customer, future customer or their agent isn’t who they claim to be.