Explanatory notes to the guidance document
The structure of the guidance document is as follows. After an introduction and a brief description of the transaction monitoring process, we present the maturity model we used in our 2016 thematic examination. For each element of the model, we explain the main findings from the examination and present the do's and don'ts resulting from our thematic examination for each component of the maturity model.
Consultation
At the end of May 2017, DNB organised round table sessions on the draft guidance document. We integrated the feedback obtained from these sessions, as well as the written response provided by the partaking institutions, into this final version of our guidance document.
[1] A cross-sectoral examination was performed at four banks, four payment institutions, three money transfer offices, and six trust offices.