AML Experts Ring in the New Year

AML Experts Ring in the New Year

In Focus

Monitoring Transactions

Question:

Not so long ago, financial institutions would disregard certain transactions and focus only on third parties; however, market practice has changed. I am looking for some official guidance on the subject.

Do you know where I can find official guidance to know if same beneficial owner transactions are not excluded from monitoring? On the other hand, have you ever read any comments or discussions around the importance of reviewing transactions between same “account holder” or “beneficial owners,” in the transaction monitoring process?

Response:

I do think to some extent that it is important, as it may be a sign of layering. So, in order to detect smurfing or any other type of unusual patterns that could be suspicious, it’s best to also look at transfers between your own accounts of high-risk to medium-risk clients. Any guidance could be looked for in cases of the annual reports of certain financial intelligence units.

Magali Lourens, CAMS

*The question and answers found in this document are excerpts taken from the Investigations, Reporting Forum. Visit ACAMS forums to read more posts.

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