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Your risk assessment and due diligence processes help you to establish what is a normal pattern of financial behaviour for a particular customer and what is unusual or suspicious.

Your transaction monitoring program must be based on your risk assessment of your organisation, and you must document how you monitor customer transactions.

The transaction monitoring program must define the processes you follow to identify suspicious customer transactions, including:

  • unusually large transactions
  • complex transactions
  • unexpected patterns of transactions that don’t seem to have a legitimate purpose.

The program must outline the risk-based systems and controls you use to monitor customer transactions.

How you monitor transactions and develop your program depends on the size of your business or organisation and your level of money laundering/terrorism financing risk.

In some circumstances, you may need to examine and monitor the customer’s past and future transactions.

  • You should try to establish the purpose and reason for transactions and monitor their types and frequencies.
  • You should monitor the expected nature and levels of your customer’s transactions, including any future transactions.