First Derivative recently supported a client who had identified a gap in their transaction monitoring controls with queries outstanding on over 3,000 of its small business accounts.
Our team mobilised efficiently to;
- Support in the update, training and communication of an enhanced TM controls testing framework.
- Review the previous 12 months of transactions in and out of the client accounts looking for any potentially suspicious transactions.
- Investigate all large or unexpected transactions to ensure they were in line with customer’s typical behaviour.
- Analyse any international transactions to high-risk jurisdictions with weak money laundering oversight/regulations, frequent large cash deposits and the use of non-traditional payment methods such as crypto or other virtual currency.
- Submit SARs on behalf of the bank (Suspicious Activity Report) to the relevant authorities when required.
The rapid mobilisation, high quality review and identification of any outcomes allowed the client to return to BAU operating as quickly as possible with no further concerns identified.
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