Set the retention end date for the practice's AML/CTF records
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- From the file list, build a row for each program record, customer due diligence record and designated-service transaction record, with the date it was made and the type. Leave the retention end date blank.
- What the lawyer must review
- The lawyer sets the end date. Program records are kept from when they are made until seven years after they are no longer relevant to showing compliance with Part 1A, and the lawyer judges when that relevance ends. Customer due diligence records must show what was collected, how it was verified, and why that level of due diligence was applied. Transaction records must be sufficient to reconstruct the transaction. A verification request sent to a credit reporting body is kept for at least seven years after the request, and longer if designated services to that person continue so that there is a continuous seven-year gap. Records may be electronic or on paper. Suspicious matter material and customer identification are stored so that access is limited. The Privacy Act applies to the practice because it is a reporting entity, including where it would otherwise be a small business.
- Written for / version
- US
Open a jurisdiction version of this task to see which instruments apply: US
Who does what
| Role | What they do |
|---|---|
| Assistance | From the file list, build a row for each program record, customer due diligence record and designated-service transaction record, with the date it was made and the type. Leave the retention end date blank. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Sort each record into program, customer due diligence or transaction, and do not apply one retention sentence to all three.
- For a program record, write down the event that makes it no longer relevant before adding seven years.
- Confirm transaction rows are enough to reconstruct the transaction, not only a narration.
- Confirm suspicious matter records and identity records are not in a folder the whole practice can open.
Sources
- AUSTRAC: Record keeping overview · 2026-10-22
These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.