Investigations
The identification of trigger events, alerts generated by the transaction monitoring tool, and unusual transactions, activities or behaviours escalated by the first line of defence shall be a scalable and operationalized process with the objective of filing with the authorities all identified suspicious activities.
- Does your institution carefully monitor all suspicious activities and report them to the regulator on a timely basis?
- Does the suspicious activities reports (SARs) escalation process cover all the relevant data and is all required information accurately collected?
- Do the sanctions and adverse media screening tools fully cover all relationships and products, and generate the alerts in line with the requirements and the risk appetite?
- How do you proactively identify suspicious activity? On a real-time basis?
The regulator expects a noticeable level of details and investigation, therefore an effective data information capture and intelligence process shall be in place.
Large specialised and professional investigation teams are costly to maintain. The level of knowledge shall always be updated and maintained with the industry standards and practices. The investigations shall be automized and operationalized as much as possible, to be able to redirect the human resources to more complicated investigation cases.
An effective investigation procedure may reveal large criminal activities helping the police and prosecutors to link all potential bad actors in such criminal activities as Corruption & Bribery, Human Trafficking, Tax Crimes, Fraud and other predicate offences.
