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2.6.3. Intelligence-led Transaction Monitoring Approach

يسري تنفيذه من تاريخ 7/6/2021

LFIs have begun to invest in forming and developing their own intelligence units or capabilities. By establishing such units or capabilities, these units seek to maximize the use of data and information available both internally—within the LFI—and externally—across jurisdictions and businesses—in order to tackle money laundering, the financing of terrorism and illegal organisations, and fraud schemes, as well as to consolidate analytical capacity and remove any jurisdictional and business silos. This has led some LFIs to shift from a pure transaction-level monitoring approach towards adopting a “customer-level” or “network” monitoring approach. Under this approach, previous investigations can be applied to inform and refine risk models, which can then be used to customize monitoring for different business lines and customer types. These enhancements are focused on looking beyond single transactions or single customers to identify the wider network in which a customer operates—looking at the customer as an entity—enabling LFIs to manage networks of accounts and report on these networks, that in turn, increases opportunities to disrupt that network. This model moves reporting away from reports of single suspicious transactions towards suspicious entities and networks with a view on how the funds flow between them.