How do we balance GDPR with AML duties?

Use legal obligation as a basis where applicable, limit fields to what AML needs, and implement retention schedules aligned to statutory periods with documented exceptions and access controls.

Do data subjects have deletion rights for KYC files?

Requests can be restricted when retention is required by law. Respond transparently, document the basis, and delete non-essential duplicates or enrichments no longer needed.

What about profiling for fraud scores?

Inform users, document logic at a high level, enable human review for adverse decisions, and run DPIAs for high-risk models while minimizing attributes.

How to handle cross-border transfers?

Use adequacy, SCCs, or other mechanisms, assess vendor jurisdictions, and apply encryption and access controls. Maintain transfer impact assessments for audit.

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GDPR

Overview

The General Data Protection Regulation is the EU’s flagship privacy law governing how organizations collect, process, and store personal data of individuals in the European Economic Area. For AML and KYC programs, GDPR requires a lawful basis for processing, purpose limitation, data minimization, transparency, and strong security controls. Rights such as access, rectification, erasure, and objection must be operationalized without undermining legal obligations like sanctions screening or statutory retention.
Controllers must assess cross-border transfers, vendor risk, and profiling impacts, often via Data Protection Impact Assessments. Governance includes records of processing, breach notification playbooks, and role-based access. Effective programs harmonize GDPR with AML laws by documenting legal bases, segregating datasets, and limiting retention to what regulators require, proving proportionality and accountability.

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