Transaction monitoring: continuous client activity surveillance to detect, flag and report suspicious transactions under AML obligations. Intermediaries must monitor transactions by understanding clients' normal activity to detect deviations, focus on complex or unusually large transactions lacking economic purpose, set internal thresholds to flag exceptions, preserve transaction records under applicable anti money laundering law, report suspicious or legally notifiable transactions to the appropriate authority and escalate them internally, and have compliance randomly examine client transactions for suspicious activity.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Transaction monitoring: continuous client activity surveillance to detect, flag and report suspicious transactions under AML obligations.
Intermediaries must monitor transactions by understanding clients' normal activity to detect deviations, focus on complex or unusually large transactions lacking economic purpose, set internal thresholds to flag exceptions, preserve transaction records under applicable anti money laundering law, report suspicious or legally notifiable transactions to the appropriate authority and escalate them internally, and have compliance randomly examine client transactions for suspicious activity.
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