Source Document
Manual of Regulations for Banks
BSP.MORB.2023.Sec924.p35.OBL12
Manual of Regulations for Banks > 924 RECORD KEEPING > Form of records > 924
Obligation Summary
For low-risk customers, records of customer information and transactions may be kept in any form, provided they still allow individual transactions to be reconstructed as evidence for a criminal prosecution.
For low-risk customers, it is sufficient that covered persons shall maintain and store, in any form, a record of customer information and transactions, but should be sufficient to permit reconstruction of individual transactions so as to provide, if necessary, evidence for prosecution of criminal activity.
MORB, Sec. 924, p. 35 (2023 ed.) · Manual of Regulations for Banks · p. 35
Covered persons shall, likewise, keep the electronic copies of all CTRs and STRs for at least five (5) years from the dates of submission to the AMLC.
For low-risk customers, it is sufficient that covered persons shall maintain and store, in any form, a record of customer information and transactions, but should be sufficient to permit reconstruction of individual transactions so as to provide, if necessary, evidence for prosecution of criminal activity.
What This Requires.
ProfytAI Regulatory Intelligence
Type: exceptionRequires covered persons to maintain and store customer information and transaction records for low-risk customers in any form, provided the records remain sufficient to permit reconstruction of individual transactions as evidence for possible prosecution.
Relationship
Functions as a carve-out from the general "Form of records" standard set in the two preceding paragraphs of the same subsection (OBL10 originals-or-admissible-form, OBL11 electronic CTR/STR copies), relaxing the required form for low-risk customers while preserving the reconstructability requirement.
Why This Exists
Applies a risk-based, proportionate standard so banks are not held to the stricter general form-of-records requirement for lower-risk customers, while still preserving enough detail to support investigation or prosecution if needed.
Implementation Considerations
Complying typically involves applying the bank's risk-based customer classification to identify low-risk customers and confirming that whatever record form is used for them still supports reconstructing individual transactions if requested.
Interpretation Note · "It is sufficient" sets a minimum floor, not a full exemption - the records must still permit reconstruction of individual transactions for potential prosecution; "low-risk customers" is a risk-classification term tied to the bank's own customer risk categorization, not defined in this paragraph.
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