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Elements and Performance Criteria

1. Identify and analyse global risks and vulnerabilities
   • Identify a range of ML/TF risks and vulnerabilities potentially impacting on the organisation including cross border transactions
   • Research, analyse and assess types of unusual activity relevant to the industry and/or organisation
   • Explore a range of investigative techniques and analytical tools to detect suspicious matters relating to ML/TF
   • Assess risk profile of different organisational portfolios and determine allocation of resources to monitor transactions
   • Evaluate approaches for monitoring transactions appropriate for identified risks and vulnerabilities
2. Review analytical tools and reporting systems
   • Analyse the capabilities of the organisation’s manual and automatic systems and assess the appropriateness for different risk scenarios
   • Evaluate the effectiveness of the organisation’s automated transaction monitoring software in detecting unusual transaction activity
   • Review training programs to encourage staff to use intuition in further investigating unusual matters
   • Review and evaluate organisational processes for triggering and monitoring alerts and creating suspicious matter reports
   • Analyse the process and organisational procedures for evidence based investigations
   • Evaluate the processes and procedures for performing periodic effectiveness monitoring
3. Monitor the performance of analytical tools and reporting systems
   • Monitor and review alerts based on specific detection rules
   • Test and evaluate the reporting solution relevant to the detection rules
   • Manage the provision of information and training to staff about the transaction monitoring program
4. Manage the investigation of alerts and generation of suspicious matter reports
   • Investigate alerts that have been triggered based on detection rules and prioritise those with the highest risk score
   • Analyse alerts to determine if activity requires further investigation
   • Ensure organisational procedures are followed for initiating an investigative activity or case
   • Analyse and review processes related to investigated cases where no action was taken and cases escalated to a suspicious matter report level to determine whether the actions taken were appropriate
   • Implement effective feedback loops to ensure continuous improvement and training of staff
5. Analyse and report suspicious transactions
   • Analyse trends in data related to alerts, activities investigated and suspicious matters reported to determine the effectiveness of reporting systems
   • Oversee the provision of feedback to relevant staff on decisions regarding reports into suspicious transactions and activities
   • Prepare internal reports on suspicious transactions and activities according to organisational procedures
   • Prepare reports on suspicious transactions and activities for regulators, including cross border regulators, following required reporting formats
   • Manage sensitivities and protocols relating to privacy and confidentiality of information when working with multiple regulators or reporting bodies

Performance Evidence

Evidence of the ability to:

document outcomes of a review of organisational anti-money laundering and counter terrorism financing (AML/CTF) reporting system

monitor AML/CTF reporting system for suspicious transactions

oversee investigations and reporting of suspicious matters.

Note: If a specific volume or frequency is not stated, then evidence must be provided at least once.

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Knowledge Evidence

To complete the unit requirements safely and effectively, the individual must:

describe a range of money laundering and terrorism financing (ML/TF) risks and vulnerabilities, identifying areas of high priority for monitoring and reporting

compare and contrast a range of investigative techniques and analytical tools to detect suspicious matters relating to ML/TF

identify and describe reporting requirements of key regulators for the organisation

outline the circumstances appropriate for:

manual transaction monitoring

automated transaction monitoring

analyse and explain typical behaviours for what constitutes unusual industry or organisation activity including:

buying and selling in large volumes and/or value

purchase or sale of a product not previously utilised, particularly if associated with ML/TF

change in customer profile

payments to sanctioned or suspicious individuals and organisations

compare and contrast key features of automated transaction monitoring systems including:

detection rules

rule selection criteria

tuning and fine tuning of detection rules

deployment

periodic review and reassessment of effectiveness

processes to document decisions

analyse organisational processes and procedures for performing periodic effectiveness monitoring including:

purpose of detection rules and alerts

analysis of data collected for detection rules including volume of rules triggered and ratio between cases and eventual suspicious matter reports

explain organisational processes and procedures for reviewing alerts including:

examination of detection rules including electronic payment monitoring, cash and cash equivalent monitoring, trading rules and loan rules

creating and investigating cases resulting from alert monitoring

determining reasonable grounds on which the basis of a suspicion is formed

process for creating a suspicious matter report

timeliness and compliance obligations

outline key features of staff information and training programs including how to:

review alerts

investigate cases

escalate unusual activities

determine whether a suspicious matter report should be filed

outline organisational procedures for investigating suspicious activities including:

collecting and analysis of evidence

security and confidentiality including not tipping off clients or others about activity subject to investigation or reporting

explain grounds used to investigate a suspicious activity or case including:

money laundering

terrorism financing

tax evasion

analyse and explain legislative and industry requirements for reporting suspicious activities

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