Transaction Monitoring and Suspicious Transaction Reporting
Practitioner2 daysAML/CFT
Programme overview
The detection and reporting half of AML. Covers rule design and tuning, alert triage, investigation technique, and the drafting of suspicious transaction reports. Delegates investigate live style alert scenarios and draft reports that are then critiqued against what a financial intelligence unit needs to be able to act.
Who should attend
Transaction monitoring analysts, AML investigators, MLROs and deputies, fraud analysts working alongside AML, IT and data staff supporting monitoring systems, and internal auditors reviewing monitoring effectiveness.
Sectors
Banks, mobile money and payment providers, foreign exchange bureaux, insurers, SACCOs, casinos and gaming.
Modules
- What monitoring is meant to detect, and the limits of rules based systems
- Designing rules: structuring, rapid movement, dormancy reactivation, round amounts, cash intensity, cross border patterns
- Threshold setting and tuning: reducing false positives without losing true positives
- Above the line and below the line testing to prove your thresholds
- Manual monitoring where no system exists: practical approaches for smaller institutions
- Alert triage and prioritisation
- Investigation technique: building the customer picture, transaction reconstruction, open source research
- Deciding suspicion: the legal test, and the difference between unusual and suspicious
- Drafting the suspicious transaction report: narrative structure, what the FIU needs, common failings
- Cash threshold and terrorist property reporting obligations
- Tipping off and confidentiality: what you may and may not say, internally and to the customer
- Post reporting: account decisions, exit strategy, ongoing monitoring of reported customers
- Management information: monitoring the monitoring function
- Investigation clinic and assessed STR drafting
Learning outcomes
On completion delegates will be able to:
- Design and tune transaction monitoring rules for your customer base
- Triage and prioritise an alert queue
- Conduct a structured investigation and document it
- Apply the suspicion test correctly
- Draft a suspicious transaction report the FIU can act on
- Manage tipping off risk
Tools and templates provided
- Transaction monitoring rule library with suggested parameters
- Alert triage matrix
- Investigation working paper template
- STR drafting template and quality checklist
- Tuning and testing methodology note
Assessment and certification
Investigation clinic and an assessed STR drafting exercise.
Certificate of Completion.