Suspicious/Unusual Transaction Monitoring and Reporting

Any activity that is not consistent with a customer’s source of income or regular business. The system should be risk based (as there are so many transactions to monitor, they can’t all be monitored). Some items that can be monitored:

  • Daily cash in excess of reporting threshold

  • Daily cash just under reporting threshold

  • Cash activity over time to detect structuring

  • Wire transfer reports per country and value

  • Monetary instrument activity

  • Check kiting/drawing on uncollected funds

  • Significant change reports (i.e. beneficial owners, addresses, new cards out to new addresses)

  • Activity on new accounts

Typical reporting process is:

  • Procedures to identify potential suspicious transactions

  • Formal evaluation of the activity and any continuation

  • Documentation of the decision

  • Procedures to notify senior management/board of directors of SARs

  • Training on detecting suspicious transactions

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