Regulatory Alerts2025-01-21
Guidance Note on Record Keeping and Customer Identification
Issued by the Non-Bank Financial Institutions Regulatory Authority (NBFIRA), this guidance mandates specified parties to implement a risk-based approach for customer identification and maintain comprehensive records of due diligence, transactions, and beneficial ownership. Entities must verify customer identities, apply enhanced or simplified due diligence based on risk profiles such as prominent influential persons and high-risk jurisdictions, and retain records in hard copy or electronic format for twenty years following transaction conclusion or relationship termination. Non-compliance with these identification and record-keeping obligations exposes institutions to significant fines, imprisonment terms of up to ten years for document-related offenses, and mandatory suspicious transaction reporting.