There is no restriction on how the centralisation of CDD information and transaction monitoring should be performed, as long as the MIS is able to provide the reporting institutions with timely information and enable the reporting institution to detect any irregularity. In addition, the reporting institutions must be able to provide records, when required by the supervisory or competent authorities or law enforcement agencies, in a timely manner.

Reporting institutions need to assess and satisfy themselves that such arrangement of the infrastructure is in compliance with other secrecy obligations pertaining to customer information, where applicable.