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  • Automated Transaction Monitoring

    • FC-2.2.3

      Licensees must consider the need to include automated transaction monitoring as part of their risk-based monitoring systems to spot abnormal or unusual flows of funds. In the absence of automated transaction monitoring systems, all transactions above BD 6,000 must be viewed as "significant" and be captured in a daily transactions report for monitoring by the MLRO or a relevant delegated official, and records retained by the licensee for five years after the date of the transaction.

      October 2010

    • FC-2.2.3A

      In the case of trust service providers (or any other licensee that does not handle customer funds) such licensees should monitor bank statements and other records to ensure that they are aware of "significant" transactions on a timely basis.

      Added: April 2013

    • FC-2.2.4

      The CBB would expect larger licensees to include automated transaction monitoring as part of their risk-based monitoring systems. See also Chapters FC-4 and FC-7, regarding the responsibilities of the MLRO and record-keeping requirements.

      October 2010