Do reporting persons have the obligation to document the PCPs?

Yes, under Section 17A.(1)(c) of FIAMLA, the PCPs must be in writing, i.e. reporting persons should document:

• written PCPs;
• any changes to those PCPs made as result of a review or update including reports from CO and MLRO;
• the steps taken to communicate those policies, controls and procedures, or any changes to them, internally. (For e.g. staff training records); and
• record keeping must include all concreate actions taken by reporting persons to communicate those PCPs or any changes made within employees of the organization.