Screening Audit Trails: What Evidence to Retain, in What Format, and for How Long
Compliance teams routinely discover during an audit that they can prove a screen happened but not what it was screened against, at what threshold, or why an alert was cleared. Using NYDFS's 2017 findings against Habib Bank as a real example of what happens when disposition rationale goes undocumented, this post specifies the evidence set a defensible screening trail requires, the format considerations that make it usable years later, and retention periods across the US, UK, and EU.
Screening Audit Trails: What Evidence to Retain, in What Format, and for How Long
Compliance teams routinely discover during an audit that they can prove a screen happened but not what it was screened against, at what threshold, or why an alert was cleared. Using NYDFS's 2017 findings against Habib Bank as a real example of what happens when disposition rationale goes undocumented, this post specifies the evidence set a defensible screening trail requires, the format considerations that make it usable years later, and retention periods across the US, UK, and EU.