Do you perform risk grading of your customer?
Do you perfom any statistical analysis like standard deviation, z-score, above and below testing while setting threshold for transaction Monitoring ?
Do you perform Customer Segment Wise transaction monitoring where customer is classified on similar attributes?
Do you perform Backtesting, that is after you made changes in your current scenario, how does this affect the previous transactions, are any suspicious transactions identified?
Have you developed Key Performance Areas and Key Performance Indicatorts to measure the effectiveness of Transaction Monitoring System across the First, Second and Third Line of Defense?
Do you communicate to Senior Management and BOD about various aspect of Transaction Monitoring System like alerts to STR ration, serious issues and so on?
Do you communicate to FIU if there are any critical STR/SAR?
Does your transaction monitoring system maintain proper audit train from generating alerts to investigating and finally, filing STR/SAR?
Do you capture various aspects of transaction? For e.g in case of Cash Transaction, do you generate only alerts for transaction done to evade threshold reporting, or do you monitor other areas of transactions like conductors, purpose and source of transaction and so on?
Do you monitor all the types of transactions performed by your customer in your organizations?
Do you have developed seperate Trasaction Monitoring Policy or Manual ?
Does your Internal Audit/External Audit review your Transaction Monitoring System?
Do you update your transaction monitoring scenarios immediately as per the changes in Money laundering and Terrorist Financing Typologies?
