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Suspicious transaction monitoring

Suspicion is risk- and context-based and can exist regardless of amount. Monitoring should combine customer profile, typologies, linked transactions and hu

Finin2min summary

Suspicion is risk- and context-based and can exist regardless of amount. Monitoring should combine customer profile, typologies, linked transactions and human review.

Source review date: 4 July 2026. Read with the official text and the facts of the transaction.

Legal anchors

  • PML Rules definition and reporting obligations
  • FIU sector guidelines

How to analyse it

  1. Create sector-specific scenarios.
  2. Aggregate linked activity.
  3. Document alert closure rationale.
  4. Escalate promptly to principal officer.

Practical illustration

A dormant account receives rapid third-party credits followed by overseas transfers. Even if individual transactions are below cash thresholds, pattern and purpose can be suspicious.

What can go wrong?

  • Rule-based alerts with no review
  • Backlog without governance
  • Customer contacted about STR decision

Evidence pack

  • Alert file
  • Customer profile
  • Transaction graph
  • STR decision note

Decision workflow

  1. Freeze the facts and effective date.
  2. Identify the controlling Act, rule, notification, circular and jurisdictional overlay.
  3. Prepare a calculation or exposure note.
  4. Collect the evidence pack before filing, payment, signing or response.
  5. Record reviewer conclusion and assumptions.

Quick Q&A

Is the result automatic?

No. Create sector-specific scenarios.

What is the most important control?

Escalate promptly to principal officer.

What should be escalated?

Rule-based alerts with no review, especially where money, deadlines, enforcement, personal liability or irreversible transaction steps are involved.

Official source trail

Secondary commentary may help interpretation, but it is not the source of law.

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