Transaction monitoring Survey

Transaction monitoring is a key control for firms to understand and identify potentially suspicious customer activity. Current guidance on how firms can effectively monitor transactional activity in a way that is practical and proportionate to them, is sparse.

In collaboration with our associates, Avyse Partners, we will be publishing guidance specifically for wealth managers and financial advisers on how to implement transaction monitoring controls which are actually targeted and useful.

As part of this, we’d like to understand current challenges firms are facing through completion of our short questionnaire below.

If you have any questions on any of the above, please email Alexandra Roberts.

Transaction Monitoring Challenges & Best Practices Survey
Name
Name
First Name
Last Name
Is your transaction monitoring (TM) system manual, automated or a combination of the two?
Would you consider your TM system to be well integrated into your wider financial crime systems and controls?
Are you leveraging artificial intelligence (AI) or machine learning (ML) within your TM system?
Are TM alerts generated in real time?
Do you have retrospective TM alerts?
Do you review your TM thresholds and rules on a regular basis (minimum, annually)?
If yes, do you have a change management process for TM updates?
Are your TM rules currently tailored dependent on customer risk rating?
Does your TM alert process consider KYC information held for your customers?
Would you consider the level of false positive alerts to be proportionate?
Does your TM system have the capability to identify transactions to/from high risk jurisdictions?
Do your TM rules align with your firm’s risk appetite?
Would you consider your TM rules to be proportionate to the nature, size and complexity of your firm?
Do you have dedicated team member(s) working on TM alerts?
Do you regularly provide training to all staff on the identification of unusual or suspicious transactions?
Do you conduct cross-training across teams on relevant risks, typologies and case studies?
How do you rate the effectiveness of recent changes implemented in your TM system?
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