My co-worker developed that 314a checklist. Then we both attended an Interagency Anti-Money Laundering seminar where a high ranking official made a very pointed (and repeated) statement that financial institutions should NOT keep copies of the list. The instructions given were for us to keep the TRACKING number, but not the actual list.
Yes - it is counter-intuitive for those of us with compliance/audit backgrounds, and there was a somewhat heated discussion about this. I was told later that these instructions were emphatically given out by FinCEN. They have since backtracked somewhat on their emphasis, so now we are left in a hazy gray limbo on what exactly we are supposed to do.
One word of caution, if you do keep the lists with your evidence of searching, make sure you keep them in a securely locked cabinet that only a few authorized staff members can access.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'