AML-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 the Capital 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 the Capital 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