Apply heightened manual review to new and elevated-risk customers

Transaction Monitoring policy, §3.3

Beyond the rules, the AML Compliance Officer reviews customer account activity by hand for the indicators rules cannot capture: every new customer in its first 90 days after activation, Tier 2 and Tier 3 customers on their enhanced monitoring schedules, customers whose activity has changed materially from the onboarding profile, and any customer that is the subject of an internal or external concern.

Continuous

Each new customer for 90 days after activation; Tier 2 and 3 customers on their schedule; on any profile change or concern

List the customers in scope each period, review each one’s activity against its expected profile, record the review, and open an alert for anything unusual.

• Manual review record

  Per customer: reason in scope, period reviewed, reviewer, findings

• New-customer watch list

  Activation date and 90-day end date for each new customer

AML Compliance Officer

Leela can keep the 90-day window on each new customer, flag the profile changes and tier schedules that bring a customer into scope, and queue the review.

Tell Leela about your company to see whether this applies.