AML Record-Keeping Requirement under IFSCA (AML, CFT, and KYC) Guidelines, 2022

The regulated entities must maintain the relevant records pertaining to the AML measures developed and implemented in the course of the business operations. In this regard, the International Financial Service Centre Authority (IFSCA) (AML, CFT, and KYC) Guidelines, 2022 provide that the regulated entities maintain the following records for the minimum period of six (6) years:

• Records about Customer Due Diligence (covering KYC form, the details of the Customer Risk Assessment, the records pertaining to customer screening, and ongoing monitoring of the business relationships)
• Records related to the entity’s ML/FT Business Risk Assessment (the risk factors considered, the methodology adopted, the risk appetite of the entity, etc.)
• Records about transactions executed with the customers, including invoices, payments, customer correspondence, etc.
• Details of the unusual or suspicious activities observed, documents around its internal reporting to the AML Principal Officer, and the action taken by the Principal Officer
• Copy of the Suspicious Transaction Reports (STRs) filed with FIU-IND

This period of 6 years is to be considered from the end of the business relationship or completion of the transactions, whichever is later.

The records to be maintained by the regulated entity must allow the entity to reconstruct the transaction basis of the documents/details and identify the customer or parties involved. These AML-related documents and records must be in an organized manner, which can be easily retrieved and furnished to the authorities when requested, allowing them to assess the entity’s AML compliance status.

Here is an infographic highlighting the key aspects around AML Record-Keeping – the period, the records to be maintained, and how such documents/information is to be maintained.

AML India is an AML consultancy service provider, offering end-to-end AML support to entities in IFSC to stay AML compliant while mitigating the ML/FT risks. Let AML India help you navigate the AML compliance journey in accordance with the IFSCA (AML, CFT, and KCY) Guidelines, starting with designing the AML/CFT policy for your business, training the team to implement the same effectively and managing the AML record-keeping requirements.