Automated Transaction Monitoring
AML-2.2.3
Capital Market Licensees must consider the need to include automated transaction monitoring as part of their risk-based monitoring systems to spot abnormal or unusual flow of funds. In the absence of automated transaction monitoring systems, all transactions above BD6,000 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 theCapital Market Licensees for five years after the date of the transaction.Amended: January 2022
Added: October 2010AML-2.2.4
The CBB would expect larger
Capital Market Licensees to include automated transaction monitoring as part of their risk-based monitoring systems. See also Chapters AML-3 and AML-6, regarding the responsibilities of the MLRO and record-keeping requirements. Where theCapital Market Licensee is not receiving funds — for instance where it is simply acting as agent on behalf of a principal, and the customer is directly remitting funds to the principal — then theCapital Market Licensee may agree with the principal that the latter should be responsible for the daily monitoring of such transactions.Amended: January 2022
Added: October 2010