Unit of Competency Mapping – Information for Teachers/Assessors – Information for Learners

FNSAML803 Mapping and Delivery Guide
Design and monitor a reporting system for suspicious transactions

Version 1.0
Issue Date: May 2024


Qualification -
Unit of Competency FNSAML803 - Design and monitor a reporting system for suspicious transactions
Description
Employability Skills
Learning Outcomes and Application This unit describes the skills and knowledge required to design, implement and maintain a transaction monitoring and reporting system which assists organisations to identify, investigate and ultimately report suspicious matters relating to money laundering and terrorism financing (ML/TF).It applies to individuals who lead and review organisation wide activities, exercise significant autonomy, responsibility and accountability and contribute to the goals and operations of the organisation. They typically have responsibility for the establishment and review of significant programs within the organisation. They use cognitive and creative skills to review, critically analyse, consolidate and synthesise knowledge, generate ideas and provide solutions to complex problems. They use communication skills to demonstrate their understanding of theoretical concepts and to transfer knowledge and ideas to others. No licensing, legislative or certification requirements apply to this unit at the time of publication.
Duration and Setting X weeks, nominally xx hours, delivered in a classroom/online/blended learning setting.

Assessment must be conducted in a safe environment where evidence gathered demonstrates consistent performance of typical activities experienced in the AML/CTF field and include access to:

relevant legislation, regulations, standards and codes

relevant organisational records, policies and procedures

organisational reporting system for suspicious transactions or case study scenarios.

Assessors of this unit must satisfy the requirements for assessors in applicable vocational education and training legislation, frameworks and/or standards.
Prerequisites/co-requisites
Competency Field
Development and validation strategy and guide for assessors and learners Student Learning Resources Handouts
Activities 		Slides
PPT 		Assessment 1 Assessment 2 Assessment 3 Assessment 4
Elements of Competency Performance Criteria              
Element: 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
       
Element: 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
       
Element: 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
       
Element: 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
       
Element: 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
       


Evidence Required

List the assessment methods to be used and the context and resources required for assessment. Copy and paste the relevant sections from the evidence guide below and then re-write these in plain English.

ELEMENT

PERFORMANCE CRITERIA

Elements describe the essential outcomes.

Performance criteria describe the performance needed to demonstrate achievement of the element.

1. Identify and analyse global risks and vulnerabilities

1.1 Identify a range of ML/TF risks and vulnerabilities potentially impacting on the organisation including cross border transactions

1.2 Research, analyse and assess types of unusual activity relevant to the industry and/or organisation

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

1.4 Assess risk profile of different organisational portfolios and determine allocation of resources to monitor transactions

1.5 Evaluate approaches for monitoring transactions appropriate for identified risks and vulnerabilities

2. Review analytical tools and reporting systems

2.1 Analyse the capabilities of the organisation’s manual and automatic systems and assess the appropriateness for different risk scenarios

2.2 Evaluate the effectiveness of the organisation’s automated transaction monitoring software in detecting unusual transaction activity

2.3 Review training programs to encourage staff to use intuition in further investigating unusual matters

2.4 Review and evaluate organisational processes for triggering and monitoring alerts and creating suspicious matter reports

2.5 Analyse the process and organisational procedures for evidence based investigations

2.6 Evaluate the processes and procedures for performing periodic effectiveness monitoring

3. Monitor the performance of analytical tools and reporting systems

3.1 Monitor and review alerts based on specific detection rules

3.2 Test and evaluate the reporting solution relevant to the detection rules

3.3 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

4.1 Investigate alerts that have been triggered based on detection rules and prioritise those with the highest risk score

4.2 Analyse alerts to determine if activity requires further investigation

4.3 Ensure organisational procedures are followed for initiating an investigative activity or case

4.4 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

4.5 Implement effective feedback loops to ensure continuous improvement and training of staff

5. Analyse and report suspicious transactions

5.1 Analyse trends in data related to alerts, activities investigated and suspicious matters reported to determine the effectiveness of reporting systems

5.2 Oversee the provision of feedback to relevant staff on decisions regarding reports into suspicious transactions and activities

5.3 Prepare internal reports on suspicious transactions and activities according to organisational procedures

5.4 Prepare reports on suspicious transactions and activities for regulators, including cross border regulators, following required reporting formats

5.5 Manage sensitivities and protocols relating to privacy and confidentiality of information when working with multiple regulators or reporting bodies

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.

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

Submission Requirements

List each assessment task's title, type (eg project, observation/demonstration, essay, assignment, checklist) and due date here

Assessment task 1: [title]      Due date:

(add new lines for each of the assessment tasks)

Assessment Tasks

Copy and paste from the following data to produce each assessment task. Write these in plain English and spell out how, when and where the task is to be carried out, under what conditions, and what resources are needed. Include guidelines about how well the candidate has to perform a task for it to be judged satisfactory.

ELEMENT

PERFORMANCE CRITERIA

Elements describe the essential outcomes.

Performance criteria describe the performance needed to demonstrate achievement of the element.

1. Identify and analyse global risks and vulnerabilities

1.1 Identify a range of ML/TF risks and vulnerabilities potentially impacting on the organisation including cross border transactions

1.2 Research, analyse and assess types of unusual activity relevant to the industry and/or organisation

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

1.4 Assess risk profile of different organisational portfolios and determine allocation of resources to monitor transactions

1.5 Evaluate approaches for monitoring transactions appropriate for identified risks and vulnerabilities

2. Review analytical tools and reporting systems

2.1 Analyse the capabilities of the organisation’s manual and automatic systems and assess the appropriateness for different risk scenarios

2.2 Evaluate the effectiveness of the organisation’s automated transaction monitoring software in detecting unusual transaction activity

2.3 Review training programs to encourage staff to use intuition in further investigating unusual matters

2.4 Review and evaluate organisational processes for triggering and monitoring alerts and creating suspicious matter reports

2.5 Analyse the process and organisational procedures for evidence based investigations

2.6 Evaluate the processes and procedures for performing periodic effectiveness monitoring

3. Monitor the performance of analytical tools and reporting systems

3.1 Monitor and review alerts based on specific detection rules

3.2 Test and evaluate the reporting solution relevant to the detection rules

3.3 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

4.1 Investigate alerts that have been triggered based on detection rules and prioritise those with the highest risk score

4.2 Analyse alerts to determine if activity requires further investigation

4.3 Ensure organisational procedures are followed for initiating an investigative activity or case

4.4 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

4.5 Implement effective feedback loops to ensure continuous improvement and training of staff

5. Analyse and report suspicious transactions

5.1 Analyse trends in data related to alerts, activities investigated and suspicious matters reported to determine the effectiveness of reporting systems

5.2 Oversee the provision of feedback to relevant staff on decisions regarding reports into suspicious transactions and activities

5.3 Prepare internal reports on suspicious transactions and activities according to organisational procedures

5.4 Prepare reports on suspicious transactions and activities for regulators, including cross border regulators, following required reporting formats

5.5 Manage sensitivities and protocols relating to privacy and confidentiality of information when working with multiple regulators or reporting bodies

Copy and paste from the following performance criteria to create an observation checklist for each task. When you have finished writing your assessment tool every one of these must have been addressed, preferably several times in a variety of contexts. To ensure this occurs download the assessment matrix for the unit; enter each assessment task as a column header and place check marks against each performance criteria that task addresses.

Observation Checklist

Tasks to be observed according to workplace/college/TAFE policy and procedures, relevant legislation and Codes of Practice Yes No Comments/feedback
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 
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 
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 
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 
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 

Forms

Assessment Cover Sheet

FNSAML803 - Design and monitor a reporting system for suspicious transactions
Assessment task 1: [title]

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I declare that the assessment tasks submitted for this unit are my own work.

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Assessment Record Sheet

FNSAML803 - Design and monitor a reporting system for suspicious transactions

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Overall assessment result: Competent Not yet competent

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