Detecting illicit flows.
WHAT MONEY LAUNDERING IS
Making illicitly obtained funds appear legitimate.
WHAT THE STAGES ARE DESCRIBED AS
Introducing funds into the system Moving them to obscure origin Returning them as apparently legitimate
WHAT CONTROLS ARE EXPECTED
Customer verification Transaction monitoring Screening against sanctions lists Reporting of suspicious activity Record keeping A designated responsible officer Staff training
WHAT TRANSACTION MONITORING LOOKS FOR
Structuring: amounts just below reporting thresholds
Rapid movement in and out Patterns inconsistent with the customer's profile Many unrelated senders into one account Transactions with high-risk jurisdictions
WHAT SUSPICIOUS ACTIVITY REPORTING REQUIRES
Filing a report where suspicion arises.
WHAT TIPPING OFF MEANS
Telling the customer a report has been made.
WHY IT MATTERS
It is generally an offence.
WHAT THAT MEANS FOR SUPPORT TEAMS
They must not explain why an account was restricted in these circumstances.
WHAT TO BUILD
Rules and monitoring A case management process Records of every decision and its reasoning
WHAT TO NEVER DO
Ignore alerts because volume is high.
