1. Financial Record Keeping Requirements
Document Retention Schedule
- Financial statements | Permanent | Primary and backup locations |
Audit Trail Standards
- Immutable record of all financial movements
- User identification for each system entry
- Timestamp accuracy with system synchronization
- Regular integrity verification checks
2.CTR and STR Documentation
CTR Preparation Checklist
- Customer identification verification
- Transaction amount and currency confirmation
- Date and time accuracy
- Aggregation calculations for multiple transactions
- Principal Officer review and approval
- FIU submission confirmation
STR Supporting Evidence
- Customer profile and history
- Transaction details and patterns
- Documentation of suspicious behaviour
- Investigation notes and rationale
- Supporting documents (IDs, bank statements, etc.)
3. Audit Trail Maintenance
System Integrity Controls
- Access Logs: Who accessed what and when
- Change Records: Modification history with reasons
- Approval Workflows: Electronic sign-off requirements
- Backup Systems: Regular tested backups
Data Protection Measures
- Encryption standards for stored data
- Access controls based on job responsibilities
- Regular security vulnerability assessments
- Incident response plan for data breaches
4. Regulatory Reporting Compliance
FIU Reporting Timeline
Report Quality Standards
- Accuracy and completeness verification
- Timeliness of submission
- Consistency with internal records
- Readability and professional presentation
5. Budgeting for Compliance Resources
Compliance Cost Allocation
- Technology systems and maintenance
- Staff training and certification
- External audit and consulting fees
- Regulatory fines and penalty reserves
- Continuous improvement initiatives
ROI Measurement
- Reduction in compliance incidents
- Audit finding improvements
- Regulatory examination results
- Staff competency assessment scores
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