• Risk Based Monitoring

    • FC-2.2.1

      Licensees must develop risk-based monitoring systems appropriate to the complexity of their business, their number of customers and types of transactions. These systems must be configured to identify significant or abnormal transactions or patterns of activity. Such systems must include limits on the number, types or size of transactions undertaken outside expected norms; and must include limits for cash and non-cash transactions.

      October 2010

    • FC-2.2.2

      Licensees' risk-based monitoring systems should therefore be configured to help identify:

      (a) Transactions which do not appear to have a clear purpose or which make no obvious economic sense;
      (b) Significant or large transactions not consistent with the normal or expected behavior of a customer; and
      (c) Unusual patterns of activity (relative to other customers of the same profile or of similar types of transactions, for instance because of differences in terms of volumes, transaction type, or flows to or from certain countries), or activity outside the expected or regular pattern of a customer's account activity.
      October 2010