Purpose
Preserve complete and retrievable FIU reporting records for the statutory period.
Normative
Bitkaya shall retain the Article 11 report data and all other relevant reporting information for at least five years in a form that permits immediate retrieval and transaction reconstruction, and shall extend retention to ten years where instructed by the FIU for a transaction declared suspicious.
Descriptive
The retained record should include the underlying alert, investigation, decision, submitted report, acknowledgements, supporting data, subsequent requests and any retention-extension instruction.
Source reference: MOT Article 11a, including the 2024 amendment.
Assurance Assertions
- Reporting records are complete, searchable and access-controlled.
- Reported transactions can be reconstructed from retained information.
- FIU-directed ten-year holds override ordinary deletion schedules.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Procedure: PROC-AML-007 Maintain AML Records and Data Retention
- Control: CTRL-AML-007 Ensure AML Records Are Retained and Retrievable
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from MOT Article 11a.