Skip to main content

2.4. Purpose of Transaction Monitoring

Effective from 7/6/2021

The purpose of transaction monitoring is the ongoing, retrospective monitoring of customers’ and prospective customers’ transactions or activity to identify activity anomalous from normal behavior. This may, on further investigation, generate knowledge or reasonable suspicion of financial crime and thereby require reporting to the appropriate law enforcement and/or regulatory authority as an STR, SAR, or equivalent local report in line with AML/CFT regulatory and/or UAE FIU reporting requirements. LFIs may choose to use a combination of automated transaction monitoring scenarios and exception-based (manual) transaction reports to monitor for potentially suspicious activity. The aim of the alert review process is to identify and respond to potential indicators of money laundering, associated predicate offenses, financing of terrorism and illegal organisations , financing of proliferation, and any potentially unusual activity that does not align to a customer’s or account's profile including by deploying a risk-based approach. An LFI’s transaction monitoring systems and manual processes should be reviewed, assessed, and revised periodically—at least annually—and otherwise as appropriate, justified by the required circumstances. Additionally, this review should include both an evaluation of transaction monitoring system thresholds and a fine tuning of the LFI’s transaction monitoring system as well as an evaluation of its effectiveness. The individuals responsible for the review should have a proper understanding of the LFI’s framework-including the LFI's business and customer base—to generate a meaningful output.