Training Session

Importance of Documentation & Records

If it isnt written, it doesnt exist
Documentation should be for the long-term as they are main point of reference during
- LEGAL ACTION BY CUSTOMER
- CUSTOMER COMPLAINTS
- REVIEW BY REGULATORS
- REVIEW BY AUDITORS
- INTERNAL REVIEWS
- HANDOVER OF CLIENTS



The adage goes something like, Suppose you were hit by a bus tonight. Could someone pick up where
you left off in your job tomorrow?

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WHY Documentation
To PROTECT from false claims
To ESTABLISH our Rights and Obligations
Have EVIDENCE of transactions

ACKNOWLEDGEMENT OF RISKS by Investors
CLARITY of Contractual Obligation

AUDIT & REVIEWS

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Documentation Should be Clear, consistent
Clear, consistent documentation of information and analysis to be able to demonstrate that
We are conducting business within the restrictions imposed by the regulators
Customer due diligence has been appropriately done
Product features and risk have been explained to customer & confirmation has been obtained to that
effect
Typically your documentation should only document what you see, hear or smell, and thats it.
Dont give any assumptions, guesses or explanations as to why something happened, just identify what
you observe.
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Example
Customer Complains that he was not aware of fee and charges
- Refer documentation that confirms the fees/ charges

There is adverse News Report on Client
- Check if this was documented and analysed during the AML Review
- If new information then put a file note

Client Meetings
- Document important aspects in file note, so that we can refer and analyse them

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In Absence of Documentation
We feel its going to be too complicated to document








But too often what we see go wrong are the simple things
Failure to identify high-risk investors & when identified & no meaningful Enhanced Due Diligence
(EDD) on high-risk investors
Due Diligence being seen as a box-ticking exercise / a necessary hoop to jump through before client
take-on


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AFTER CLIENT SETUP
Sadly, this never ends
You must continue to monitor and document
Follow Risk Based approach

TO ASCERTAIN
If there are any complaints
If there is any mis-selling
If the customer is getting services as per commitment

DOCUMENTS THAT WILL BE REFERRED TO
RM Note on Client Meetings
Communication from/ to Client
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COMMON EXCUSES
If I document it, I'll know where it is but never need it
I don't want to remember the past.
It is not in my nature
I don't want anyone to know what I do
None of my clients are complaining
I was stressed out
I was busy
This is very urgent

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Document...document...document

Always document..it indicates you've been working