Record keeping obligations require intermediaries to retain transaction and customer records for audit trails accessible to investigators.

Intermediaries must maintain comprehensive record keeping to permit reconstruction of individual transactions, identifying beneficial owners and transaction volumes. For selected transactions they must document origin and destination of funds, form of funds, identity of the transacting person, and form of instruction and authority. Customer and transaction records must be available promptly to investigating authorities, and intermediaries should consider retaining customer identification, account files and business correspondence beyond statutory periods to preserve an audit trail for suspected money laundering or terrorist property investigations.

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