AML/CFT: organizing your compliance (procedures, training, data retention)

Beyond the checks carried out on each sale, AML/CFT requires a genuine internal organization Who does what, what training is required, and how is evidence stored? The practical aspects, in addition to our... vigilance obligations.

The essentials in 30 seconds

• Organize the circulation of alerts : who controls, who decides, who declares.
• Form the managers and the salespeople.
• Keep the supporting documents for five years.
• A software is not mandatory, but it saves time.

Organize the internal procedure

You must organize the flow and processing of alerts within the company, determining who:

• performs the checks; ;
• analyzes unusual situations; ;
• decides whether or not to continue the business relationship; ;
• is authorized to transmit a suspicious activity report; ;
• responds to any requests from TRACFIN; ;
• and how evidence of the checks is kept.

In a small business, the functions of declaring and TRACFIN correspondent can be entrusted to the same person.

Training managers and salespeople

Managers and relevant staff must receive regular information and appropriate training (as required by the Monetary and Financial Code). In particular, your salespeople must know:

• recognize risky situations; ;
• request the necessary supporting documents; ;
• escalate an alert internally; ;
• not to inform the client of a possible declaration; ;
• maintain a suitable business attitude, without turning the interview into an interrogation.

Keep the documents for five years

Documents relating to the client, beneficial owners, transactions and due diligence measures are retained five years : from the end of the business relationship, or from the completion of the transaction for a one-off client. Also keep the analyses of complex or unusual transactions. The file is not limited to a copy of identification: it must demonstrate the controls carried out, their results and the decisions taken.

Is AML/CFT software mandatory?

No. The law does not mandate any specific software: the procedures can theoretically be carried out manually. However, a tool can facilitate identity verification, the search for beneficial owners, the monitoring of PEPs and asset freezes, the traceability of searches, the retention of supporting documents, the processing of alerts, and the preparation of an audit file.

Warning: software does not transfer responsibility. The decision to carry out a transaction, to request supporting documents, or to report a suspicion remains with the professional.

For the complete procedure and timeline, return to the guide. AML/CFT: What are the obligations for HBJO professionals?

This article is for informational purposes only and does not replace applicable laws or professional advice. The AML/CFT framework is technical and constantly evolving: verify your situation with official sources (Monetary and Financial Code, French Customs and Indirect Tax Authority (DGDDI), French Financial Intelligence Unit (Tracfin)) or a professional before deciding on your specific measures.