The CBB would expect larger Capital Market Service Providers 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 the Capital Market Service Provider 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 Capital Market Service Provider may agree with the principal that the latter should be responsible for the daily monitoring of such transactions.
October 2010