6 RECORD KEEPING AND DOCUMENTATION
6.1 There should be adequate documentation by the insurer for the basis of clearing or dismissing hits arising from its screening procedures (i.e. false positive hits). As a good practice, additional parameters such as date of birth and nationality should minimally be used to establish and dismiss false hits.
6.2 There should be documentation and maintenance of proper records by the insurer as to when screening was performed, the results of the screening and the assessment of screening results for all policies.
6.3 A record of all transactions referred to the Suspicious Transaction Reporting Office (“STRO”) should be maintained by an insurer, including the relevant internal findings and analysis.
6.4 In cases where an insurer maintains an internal database containing the list of designated individuals and entities for the purpose of screening, there should be clear documentation of when the internal database was most recently updated, as well as of the name of the person who carried out the update.