On 15 July 2020 the Malta Financial Services Authority (the
"MFSA") issued a circular addressed to
all licenced entities regarding their obligations in relation to
record keeping.
The MFSA expects that licenced entities retain accurate
documentation and records relating to their governance and
oversight of regulated activity and their interaction with
customers, in order to enable the MFSA to properly supervise them
and protect customers.
In this regard, the MFSA outlined in the circular that the
record keeping obligation extends to interactions with potential
clients, whether or not they are eventually onboarded. Licenced
entities are required to ensure that all correspondence relating to
client contact and introduction, client acceptance, client on
boarding as well as all ongoing correspondence throughout the
relationship are retained centrally.