Transaction Monitoring Should Be Included In Your Company’s Compliance Program

by Mike Mintz on December 8, 2011 · 1 comment


Many opine that the techniques used in anti-money laundering should be used in banking and other financial institutions’ compliance programs.  More specifically, Thomas Fox, in his article “Transaction Monitoring: Fighting Corruption and Protecting National Security” states that these institutions should adopt the method of transaction monitoring into their compliance programs.

Many compliance programs succeed in monitoring Politically Exposed Persons’ (PEPs) transactions and in investigating “red flags” under the Foreign Corrupt Practices Act (FCPA).  However, Fox believes that companies fail to integrate transaction monitoring into their compliance programs.

To do this, companies’ treasury and legal departments should notify each other of suspicious payments, as well as share documentation of all such payments.  In addition, these departments should monitor each transaction to determine if it is “suspicious” and have a system in place to perform the same suspicious activity analysis in the normal course of transacting business.  In fact, there are software programs, which will automate this monitoring process for you.

Fox ends his article predicting that “as banks and other financial institutions become more robust in their anti-money laundering programs, many nefarious individuals may move their activities to companies with less robust procedures and back-up systems to detect, record, store and share any such activity with the appropriate group within a company. This may well be the next US government target for inquiry.”

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