BMA would expect larger investment firm licensees to include automated transaction monitoring as part of their risk-based monitoring systems. See also Chapters FC-3 and FC-6, regarding the responsibilities of the MLRO and record-keeping requirements. Where the investment firm 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 the investment firm licensee may agree with the principal that the latter should be responsible for the daily monitoring of such transactions.