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2.6.1. Manual Monitoring

Effective from 7/6/2021

An LFI may seek to utilize a manual transaction monitoring system, which typically targets specific categories of transactions (e.g., those involving large amounts of cash, those to or from certain geographies) and includes a manual review of various reports generated by the LFI’s systems in order to identify unusual activity. The type and frequency of reviews and resulting reports used should be commensurate with the LFI’s AML/CFT risk profile—including the nature, size, and complexity of its operations—and properly cover customers, counterparties, businesses, products, services, delivery channels, and geographic markets. System-generated reports typically use a certain currency threshold to detect unusual activity. An LFI’s responsible senior employee should periodically evaluate the appropriateness of filtering criteria and thresholds used in the monitoring process and periodically appraise Senior Management and where required, notify the Board of Directors (as part of periodic updates), on the appropriateness of design of manual monitoring reports. LFIs should be alert to the fact that complex and evolving financial crime risks can undermine the effectiveness of manual monitoring systems, and therefore, manual monitoring systems should also be independently reviewed for reasonable filtering criteria.