- 11 - b. Implement an ongoing training program to ensure that employees are kept informed of all the aspects of the anti-money laundering and combating terrorism financing requirements, new developments, money laundering and terrorism financing techniques, methods and trends, and concerning due diligence measures and suspicious transaction reporting; c. Establish an independent audit function to verify compliance with the internal policies, procedures, systems and controls and to ensure that such measures are effective and consistent with the provisions of this Law; d. Put in place mechanisms for the sharing with other members of the financial group of information obtained under Articles 4 and 5, and to protect the confidentiality and use of exchanged information; and e. Designate a compliance officer at the senior management level to be responsible for the implementation of the requirements of this Law. As appropriate, the measures under this Article shall apply to all domestic and foreign branches and their subsidiaries. Article 11 Financial institutions and designated non-financial businesses and professions shall maintain records of the following information and ensure that such records and underlying information are available to competent authorities: a. copies of all records obtained through the due diligence process under Article 5, including documents evidencing the identities of customers and beneficial owners, account files and business correspondence, for at least five years after the business relationship has ended or a transaction under Article 5 (3)(b) has been carried out;; b. all records of transactions, both domestic and international, attempted or executed for at least five years following the attempt or execution of the transaction. Such records must be sufficiently detailed to permit the reconstruction of each individual transaction; c. Copies of transaction reports sent under Article 12 and related documents for at least five years after the date the report was made to the Unit; and d. The risk assessment under Article 4 and any underlying information for a period of five years from the date it was carried out or updated. A competent authority may require in specific cases that records be maintained for longer than the periods prescribed under this Article.