Guidance on the transaction monitoring process at banks

These findings show that banks do not yet sufficiently control their transaction monitoring process with respect to money laundering and terrorist financing risks. The documents presents the main outcomes of the examination and offers guidance on how to improve the transaction monitoring process. When developing solutions and measures you should of course take into account your institution's own circumstances. You have to make your own considerations in this respect.

Explanatory notes to the guidance document

The structure of the guidance document is as follows. Following 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 good practices and examples of what not to do.

Round-table counsultation meetings

In May and June 2017, we organised three round-table meetings to discuss the draft guidance document, two with the relevant first- and second-line staff, respectively, and a third for external advisors. The feedback we collected during these meetings and the written responses we received were incorporated in the final version of the guidance document, which was published in August 2017.

^[1] A cross-sectoral examination conducted in various sectors (four banks, four payment institutions, three money transfer offices, and six trust offices).