The Importance of Effective Transaction Monitoring

On-going monitoring includes scrutinising transactions undertaken throughout the course of a business relationship and is a key AML/CFT control, which can take the form of both automated and manual monitoring.

In their recent feedback paper, the ‘Thematic Review: Compliance Monitoring Plan’, issued in October 2021, the Jersey Financial Services Commission (“JFSC”) states:

• Effective monitoring of transactions is an invaluable process that enables senior management to demonstrate that they have implemented and maintained adequate and effective systems and controls (including policies and procedures), that they are being complied with, and that timely action is being taken to remedy any deficiencies brought to their attention.
• Effective compliance monitoring also facilitates senior management’s risk assessment of their organisation’s compliance with its statutory obligations and regulatory requirements. Where heightened risks are identified or non-adherence to the regulatory framework is highlighted, then matters can be proactively escalated and managed.

Transaction monitoring refers to the scrutinization, examination and review of your customer’s transactions. The aim is to identify, prevent and report suspicious activity to your MLRO in a Suspicious Activity Report (“SAR”).

The team at Baker Regulatory Services (“BRS”) have between them decades of unrivalled experience in undertaking effective Transaction Monitoring and can share their knowledge and experience with you through effective and well-structured training sessions. They will also be able to take you through the recent feedback issued by the JFSC and share what they consider to be best practice.

If you would like to receive further information, please contact myself (Sharon Sargeant) or Barry Faudemer below.