We focus on the effectiveness and efficiency of your record-keeping policies to make sure they are fit for purpose in your circumstances, aligning them with:
- Your commercial goals
- The size of your business
- The available technology for document retention and information management
- The available resources
- Your governance and operational structures
- Your client base
- Your countries of operation
- Your client acceptance policy, overall risk management framework and risk appetite
- Applicable compliance obligations covering document retention and data privacy, including, but not limited to, obligations under the applicable privacy laws, anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations, financial market laws, FATCA/CRS related obligations, any licensing, regional or license-related product offering limitations and obligations and more
Our solutions cover:
- Record-Keeping Policy Design: Developing tailored policies and procedures to meet jurisdictional and industry-specific compliance obligations for different types of businesses (startups, company groups, high-risk corporates, etc.)
- Record-Keeping Policy Enhancements: Reviewing and improving existing record-keeping frameworks to address gaps, changes in regulations, and business needs.
- Training for Record-Keeping Teams: Delivering tailored training for staff to optimise record-keeping processes, comply with regulatory requirements, and maintain audit readiness.
- Technology Integration for Record-Keeping: Assisting with the selection, integration, and testing of digital solutions for automated record tracking, archiving, and retrieval.
- Record-Keeping Policy Implementation: Leading and coordinating the implementation of record-keeping frameworks, managing milestones, ensuring cross-departmental collaboration, and aligning deliverables with compliance and operational objectives.
Our focus areas include:
- Retention schedules
- Automated compliance reporting
- Internal controls for record-keeping
- Compliance with privacy regulations
- Record-keeping policies and procedures
- Data protection and encryption measures
- Audit-ready documentation practices
- Compliance-focused data management
- Secure storage solutions
- Access control protocols
- Regulatory reporting integration
- Data accuracy and completeness
- Archiving and retrieval systems
- Incident reporting documentation
- Data lifecycle management
- AML/CFT record-keeping compliance
- Licensing-related record requirements
- Gap analysis for record management
- Transaction data retention
- Suspicious matter reporting documentation
- KYC record maintenance
- Enhanced due diligence record protocols
- Sanctions screening documentation
- Customer account record requirements
Services Coverage
We offer record-keeping policies and procedures to various financial institutions, financial service providers, and other reporting entities subject to data retention and regulatory compliance requirements, including but not limited to:
- Investment bankers
- Investment firms
- Fund managers
- Brokers, including forex brokers
- Fintech companies
- Non-bank deposit takers
- Non-bank lenders
- Online casinos and gambling platforms
- Currency exchange providers
- E-money issuers
- Money remitters and money transmitters
- Payment gateway providers
- Derivatives issuers and platforms
- Neo-banks
- P2P lending platforms
- Crowdfunding services and platforms
- Financial advisers
- Investment advisers
- Wealth managers
- Custodial or depository service providers
- Consumer credit providers
- Building societies
- Savings and loan associations
- Credit unions
- Corporate finance providers
- Finance companies
- Designated non-financial businesses and professions (DNFBPs), including trust and company formation providers (TCSPs)
Jurisdictional Coverage of Our Record-Keeping Solutions
We deliver record-keeping and data retention policies across the following jurisdictions, including but not limited to:
- Australia
- United Kingdom
- United States
- Singapore
- European Union
- New Zealand
- Prominent formation centres, including:
- Belize
- British Virgin Islands
- Cayman Islands
- Dubai
- Bermuda
- Panama
- Jersey
- Malta
- Mauritius
- Seychelles
- Vanuatu
Record Keeping Policy and Data Retention Policy Design
We offer well-designed data privacy compliance programs that cover:
- Data Protection Compliance: Addressing obligations under privacy laws like GDPR, CCPA, or local equivalents.
- AML/CFT Record-Keeping Compliance: Meeting jurisdiction-specific record-keeping obligations for anti-money laundering and counter-terrorism financing.
- Licensing-Related Record Requirements: Ensuring compliance with industry-specific licensing conditions for record retention.
- Secure Digital Record Solutions: Implementing encrypted and secure systems to maintain data integrity and privacy.
- Regulatory Audit Preparation: Providing structured processes to ensure all records are audit-ready and traceable.
- Integration with Compliance Frameworks: Aligning record-keeping policies with broader risk management and compliance programs.
- Privacy Impact Assessment (PIA): Conducting structured assessments to evaluate the privacy risks associated with record-keeping and data retention practices, ensuring compliance with applicable data protection laws and minimising potential data breaches.
- Compliance with ISO Standards: Aligning record-keeping and data retention policies with ISO standards such as ISO 27001 (Information Security Management).
Record Keeping Policy and Data Retention Policy Review
We offer thorough record-keeping and data retention policy reviews to assess its effectiveness and fitness for purpose. Our focus areas include identifying:
- Any gaps
- Points of improvement
- Required adjustments related to changes in your resources and operations
- Required adjustments related to the introduction of new products, expansion to new jurisdictions, and more
Record-keeping Policy Implementation
When it comes to assisting businesses with their record keeping or/and data retention policy rollout, our focus areas include, but are not limited to:
- Training teams across various departments to understand and execute record-keeping and date retention-related responsibilities.
- Creating a set of effective manuals, procedures and protocols that cover each statement or action required to be taken in the policy
- Creating effective manuals, procedures, and protocols detailing the actions required under the policy
- Developing internal controls for data management, as well as linking them to compliance monitoring program/internal controls testing plans of the busines,s and reporting on compliance testing for data management
- Managing regulatory submissions related to data retention
- Implementing mechanisms to track and manage retention periods for different types of records in compliance with regulatory requirements
- Creating protocols for classifying data and ensuring that access is restricted based on roles and responsibilities
- Assisting business to align their data disposal processes with their regulatory obligations
- Assisting businesses with developing contingency plans for accessing records during disruptions, such as system failures or cyberattacks.
- Recommending tools for automated record-keeping, retention tracking, and regulatory compliance reporting, including systems to maintain an audit trail for record-keeping activities
Record-keeping Compliance Enhancement
We can help with your record-keeping compliance enhancement to increase its overall effectiveness, reflecting on:
- New compliance requirements, changes to the existing regulatory regime, and adaptations to regulatory compliance guidance
- Policy updates for regulatory changes
- Business growth and expansion
- Changes in risk ratings, risk appetite, identified new risks, and changes in risk profiles
- Auditors' and regulators' findings, including identified deficiencies and breaches
- Gap analysis for compliance improvements
- Results of previous internal controls testing
- Introduction of new products
- Enhanced retention protocols, the new data accuracy verification tools
- Process optimisation for efficient record-keeping
- Secure data storage advancements
- Audit trail refinement
- Other triggering events
Record-keeping Compliance Implementation
Our focus areas for this service include:
- implementation of retention policies
- training on record-keeping protocols
- system integration and migration
- compliance testing for data management
- incident reporting documentation setup
- secure storage solution deployment
- alignment with data privacy regulations
RegTech Solutions for Data Management
Our focus areas for this service include:
- Needs Assessment
- Record-Keeping Technology selection: Tailored to your budget, operations, and compliance obligations
- Implementation and customisation assistance: record-keeping technology integration assistance across the business.
- Testing: Assisting with testing to validate functionality, usability, and integration with operational, risk management, and compliance structures
- Internal Documentation Alignment: Streamlining internal documentation, including data management and record-keeping policies, procedures, workflows, and process maps, to accommodate the technology selection
- Automated reporting solutions
- Analytics and data-driven insights
- Automated compliance reporting
- Real-time validation tools for customer onboarding, fraud prevention, transaction monitoring and other regulatory obligations
- Secure digital archiving
- Workflow automation for record-keeping
Record-keeping Compliance for Small Businesses and Startups
Gaps in record-keeping requirements are a common issue in startups' and small businesses' compliance management. This is particularly true when using cost-effective digital solutions without tailored record-keeping advice. Changing compliance tools and processes as you grow without considering record-keeping obligations further compounds the issue.
When facing an audit or review, responses to record-keeping questions often sound like: "We used this tool three years ago. We do not keep the data; it is with a provider we offboarded three years ago."
Data retention requirements under various laws and regulations (e.g., anti-money laundering and counter-terrorist financing laws and regulations, financial licensing regimes, FATCA and CRS provisions) typically range between five and seven years.
We focus on helping you maintain compliance from the get-go, creating an effective foundation for future growth. Our services include linking your record-keeping obligations and procedures to:
- cost-effective digital solutions
- scalable storage frameworks
- easy-to-use data management tools
Multi-Jurisdictional Record-Keeping Solutions
Managing record-keeping across multiple jurisdictions and/or entities is all about paying attention to detail and being able to provide. It is about navigating local regulations and laws with a nuanced approach to legal requirements and different aspects of financial and operational regulation. Resource allocation is about focusing on where things matter and balancing attention to detail with overall efficiency.
Our years of experience with multi-jurisdictional financial institutions allow us to tailor your record-keeping compliance management across diverse business units and locations effectively. We focus on:
- Centralised data management platforms
- Group-wide compliance alignment
- Standardised policies across entities
- Integration with governance frameworks and compliance monitoring programs
- Unified reporting mechanisms
Record-keeping Compliance for High-risk Corporates
High-risk corporates face heightened regulatory scrutiny and reviews. With years of experience helping high-risk corporations go through audits and reviews successfully, we offer record-keeping solutions that account for robust and holistic reviews. Our focus includes, but is not limited to:
- Enhanced data retention protocols tailored to regulatory and operational needs
- Stringent access control measures to protect sensitive and critical records
- Effective record management systems for accurate storage, retrieval, and tracking of data and record
- Detailed audit trails for high-risk transactions
- Tailored retention frameworks for complex operations
