For compliance and engineering teams retaining screening decisions
What evidence should you retain for a screening decision?
A screening decision has to be reconstructable long after the moment it was made, by a reviewer, an auditor, or a regulator. A stored match percentage cannot do that. This page lists the fields worth retaining, how long record-keeping obligations typically run in the EU, and how to keep the evidence retrievable and tamper-evident.
Primary sources
- Directive (EU) 2015/849 (4th AMLD), Article 40, record retention
Obliged entities must retain the records underlying CDD and transactions for five years after the end of the business relationship or the date of an occasional transaction (subject to national extensions).
- FATF Recommendation 11, record-keeping
Financial institutions should keep all necessary records on transactions and CDD for at least five years so that individual transactions can be reconstructed.
- Regulation (EU) 2024/1624 (AML Regulation), single-rulebook record-keeping
The EU's new AML Regulation carries record-keeping obligations forward into a directly-applicable single rulebook; confirm the applicable dates and any national specifics for your entity.
Why a score is not a record
A similarity score answers one narrow question: did anything resemble this name? It cannot tell a reviewer which alias matched, which source was current, whether the candidate set was complete, or whether an unavailable list was mistaken for a pass. A record has to carry those facts, because those are the facts an audit turns on.
The fields below map to the open Screening Decision Record, so what you retain is the same shape as what a screening API should return in the first place.
The fields to retain
| Field | Why it is on the record |
|---|---|
| Input (raw + normalized) | What was submitted, and what was actually screened after normalization and transliteration. |
| Screening mode | Standard (recall-oriented) vs a narrow exact-only lookup that cannot support a clearance. |
| Sources + list versions + state | Every source consulted, its exact version, and whether it was current, stale, unavailable or excluded. |
| Coverage status | Complete / partial / unavailable, an unanswered in-scope source is on the record, not hidden. |
| Candidate set completeness | Whether the candidate set was exhaustive or capped; a capped set cannot clear. |
| Reasoning | The signals that moved the result, kept separate from any analyst-confirmed identity. |
| Served decision + eligibility | The machine outcome and whether a no-hit was eligible to be treated as clear. |
| Human disposition | The analyst action, recorded separately from the machine result. |
| Evidence state + integrity | Whether the decision can be reconstructed, plus a content-integrity hash. |
| Policy version + timestamps | The policy and plan scope in force, and when it was screened and recorded. |
How long to keep it
In the EU, the baseline is five years of retention for CDD and transaction records under the AMLD (and FATF Recommendation 11 sets the same floor internationally). Some member states extend this, and the timer generally runs from the end of the business relationship or the date of the occasional transaction.
Retention length is only useful if the record is retrievable and its integrity checkable for the whole period, a record you cannot produce, or cannot prove is unchanged, is not evidence.
Limitations
- Retention periods and their triggers vary by member state and by entity type; five years is a floor, not a universal answer. Confirm your specific obligation.
- A content-integrity hash detects change; it is not an external timestamp, notarization, or independent attestation.
- Retaining evidence supports review; it does not by itself discharge any compliance obligation or make a decision defensible on its own.
- There is a storage-limitation tension with data-protection law: keeping personal data beyond the statutory retention period can itself be a breach, so 'keep everything forever' is not a safe default. Retain for the required period, not indefinitely.
- This page is an implementation reference, not legal advice.
Build the evidence, not just the alert
Questions
Is storing the API response enough?
It can be, if the response carries the fields above, input, sources and versions, coverage, candidate completeness, decision, eligibility and an integrity hash. If it only stores a score and a label, it is not a reconstructable record.
How does Verifex retain this?
Each screening can seal an Evidence Capsule: a self-contained record of the fields above plus a content-integrity hash, retrievable by request or capsule ID. Where a durable record is not available, the response says so rather than implying one exists.
Does five years start at the screening date?
Usually not. Under the AMLD the clock generally runs from the end of the business relationship or the occasional transaction, which can be well after the screen. Check your national transposition.
This page is an implementation reference for engineering and compliance teams. It is not legal advice and does not certify any regulatory outcome. Regulatory obligations, their interpretation, and the decision to treat any result as clear remain yours. Verifex supports the workflow and preserves the evidence; it does not make the compliance decision.