Regarding preservation of transaction records, etc. and reporting of suspicious transactions, etc.
Posted: May 2017, 6
Hello. My name is Shimizu and I am in charge of the funds transfer business.
Last time, I wrote about "confirmation at the time of transaction".
This time, it's a continuation.
In addition to "confirmation at the time of transaction", there are certain things that the funds transfer service provider should do.
These are "preservation of transaction records, etc." and "reporting of suspicious transactions, etc."
Failure to do so is a violation of laws and regulations and may result in disciplinary action or punishment.
Now let's look at them in turn.
1. What does it mean to save transaction records?
Preservation of transaction records, etc., in layman's terms, means:
``Make sure to keep records of your transactions.''
When a funds transfer service provider receives a request from a user and conducts a remittance transaction,
Records of those transactions must be kept.
So, how do you save transaction records?
The flow will be as follows.
① Creation and preservation of confirmation records → ② Creation and preservation of transaction records, etc.
First, create a "confirmation record".
Specified business operators are obligated to create confirmation records when confirming transactions.
The confirmation record includes the following items.
・Things confirmed in "Confirmation at the time of transaction" (identification matters, purpose, occupation/business, etc.)
・How was the confirmation performed at the time of the transaction?
・Others (*Matters specified by ordinance of the competent ministry)
Then, these confirmation records are stored from the contract termination date of the transaction.
Must be kept for 7 years.
This is about creating and saving confirmation records.
After creating and saving the confirmation record,
Start creating and saving "transaction records, etc."
What are transaction records? That being said,
・Matters for searching confirmation records
・Date and content of the transaction and other matters specified by ordinance of the competent ministry
・Matters in Article 7, Paragraph 2
In "Matters for searching confirmation records" such as transaction records,
This is an image of searching and linking many "confirmation records".
Legally, the flow is "confirmation record → transaction record",
However, in practice, "confirmation records" and "transaction records, etc."
You probably create and save them at the same time.
Next, we will explain about "Suspicious Transaction Reports, etc."
Roughly speaking, at the time of transaction confirmation,
Or are you doing any of the following? I'll take a look.
・Article 10 of the Organized Crime Punishment Act
Notifying matters specified by Cabinet Order in a manner specified by Cabinet Order;
This is the rule.
The problem for businesses here is:
I think you're asking, "How do you decide?"
User attributes such as nationality, official status, business the user is conducting, etc.
Distinction between foreign exchange transactions and domestic transactions, and transaction types such as transaction amount and number of transactions based on user attributes
It is said that such things should be taken into consideration.
It is also necessary to create a system that can detect, monitor, and analyze these.
If you wish to report a suspicious transaction,
You must not divulge the fact that you are submitting a report or what you have done to users or related parties.
We may also carry out remittance services,
In that case, check whether those partners have similar systems in place.
You also need to check this, so be careful.
Moreover, the operator
・Measures to keep information related to matters confirmed at the time of transaction up to date
These are required when registering a funds transfer business, so
Please take care of these before applying for registration.
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