The next instalment from Firmchecks AML Essential Kit covers record keeping, which is about more than storing documents — it’s how your firm proves it has met its compliance obligations.
AML record keeping is about more than storing documents — it’s how your firm proves it has met its compliance obligations.
You’re required to keep clear, accurate records covering due diligence, risk assessments, transactions, policies, and any suspicious activity. These must be securely stored, regularly updated, and retained for at least five years.
Good record keeping protects your firm during audits, supports internal reviews, and helps you manage risk effectively. With the right tools, training, and consistency, it becomes a key part of a strong, compliant AML framework.
AML record keeping refers to the documentation your firm is legally required to maintain as part of its anti-money laundering obligations. These records include everything related to customer due diligence (CDD), risk assessments, transaction history, internal reports, policies, and procedures. Record keeping is required by regulation 40 of the Money Laundering Regulations (MLR 2017) and supports the full AML lifecycle — from client onboarding to ongoing monitoring and reporting suspicious activity.
AML record keeping isn’t just about storing documents. It’s about demonstrating that your firm is taking its responsibilities seriously and has the evidence to back it up. Done well, record keeping helps your firm to:
Stay compliant with MLR 2017, POCA, and the Terrorism Act
Protect against reputational damage and enforcement action
Provide an audit trail for decisions made, including client acceptance and SARs
Respond confidently to compliance reviews or supervisory visits
Monitor high-risk clients and spot trends over time
Refine your AML policies with real-world context and data
Failing to maintain proper records can result in financial penalties, restrictions on practice, and even criminal liability in serious cases.
Read the full guide now to learn more on how to manage AML record keeping effectively:
Keep the right types of records
Follow legal retention periods
Make records accessible and secure
Train your team on what to keep and how
Tailor templates and tools to your firm
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