Belgium

Art. 9 §1 requires legal-person obliged entities to appoint, from their statutory governing body or senior management, the person responsible at the highest level for supervising implementation of and compliance with the Law. Art. 9 §2 requires one or more operational persons, vetted in advance for integrity, expertise and independence; the CTIF-CFI describes this person as the AMLCO. Art. 8 §2 lists the policy areas that internal policies must cover, including record-keeping.

Art. 60 1°-2° requires identification data, supporting documents and verification records to be kept for ten years from the end of the business relationship (or from an occasional transaction). Art. 60 3°-4° requires transaction records and the written reports on atypical transactions to be kept for ten years from execution of the transaction. Art. 62 §1 requires personal data to be deleted when these periods end.

Art. 10 requires staff to be able to report non-compliance with the Law through a specific and independent channel, confidentially and anonymously, to the persons appointed under Art. 9.