AML/CFTR 4.3.14 Procedures for ongoing monitoring

(1) A firm must have policies, procedures, systems and controls for ongoing monitoring for its customers.
(2) The systems and controls:
(a) must flag transactions for further examination; and
(b) must provide for:
(i) the prompt further examination of these transactions by a senior independent person;
(ii) appropriate action to be taken on the findings of the further examination; and
(iii) if there is knowledge or suspicion of money laundering or terrorism financing raised by the findings — a report to be made promptly to the firm's MLRO.
(3) The monitoring provided by the systems and controls may be:
(a) in real time (that is, transactions are reviewed as they take place or are about to take place); or
(b) after the event (that is, transactions are reviewed after they have taken place).
(4) The monitoring may be, for example:
(a) by reference to particular types of transactions or the customer's risk profile;
(b) by comparing the transactions of the customer, or the customer's risk profile, with those of customers in a similar peer group; or
(c) through a combination of those approaches.
Derived by QFCRA RM/2019-8 (as from 1st February 2020)