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October 4, 20269 min read

Seven-year AML record keeping after the file closes

Seven-year AML record keeping is the period firms plan for. The day the folder leaves the desk is not automatically the day the period starts.

Quick answer

Keep the customer records your program says you must be able to show, and ask the obligations material whether the period runs from the transaction, the end of the relationship, or the making of the record. This page does not reproduce those rules. Closing the file is an office event, not by itself the legal start date. The firm suite is A$0.

People search “AML record keeping 7 years” when a firm boxes a finished matter on Friday and assumes the seven years started when the lid went on. Checked against the AUSTRAC Tranche 2 obligations factsheet on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Watching a customer while the matter is open is ongoing customer due diligence for a small firm. What the check record contains is what an AML check covers. The sector map is /tranche-2.

Archive day is an office date

Firms talk about seven years because that is the retention period they plan around for AML/CTF records. The obligations factsheet is a short frame. This page does not reproduce the record-keeping rules and does not pick the start date for you.

Write two dates on the closed file: the day you archived it, and the day your program says the retention period runs from. If you only have the first date, you have a storage habit. You do not yet have an answer a reviewer can follow. Destroying a box because “it feels old” is not the rule.

  • Keep what the program named. The check result, the customer you relied on, and the decision to proceed or stop. A bundle of unmarked scans is not that set.
  • Do not start the clock from the archive stamp alone. Ask which event the obligations material uses for that kind of record. This page will not invent the event.
  • Keep access with the firm. The person who can find the file next year should not need a former vendor’s password. Export is a different page if you are changing software.
  • Ongoing monitoring is while the customer is current. Once the file is truly closed, retention is the question. Do not call a closed box “ongoing due diligence”.

Closed file, still a record

Sort the closed cabinet before you sort the shredder. Most arguments are about the start date, not about whether AML records are kept at all.

A sorting aid after the matter ends. This table does not reproduce AUSTRAC’s record-keeping rules.

Date you might writeWhat it actually isDo not assume
Day the folder was boxedAn office eventThat the seven years started that morning
Day of the transactionA candidate start, if the rule for that record says soThat every record uses it
Day the customer relationship endedAnother candidate, if the rule says soThat a quiet client has ended the relationship
Day you made the recordA third candidate for some recordsThat this page has chosen it for you

Where the seven-year page stops

This page is retention after the file closes. It is not ongoing monitoring and it is not a description of the check result. Those are ongoing customer due diligence for a small firm and what an AML check covers.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Storing the seven-year archive is the firm’s job, and that archive is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not store your records for seven years or decide when the period starts.

Frequently Asked Questions

Keep the record. The next check is still client-pays.

The firm suite is A$0. The client pays a new verification. The old record stays with the firm.

View pricing

Questions: team@freeaml.com.au