Indepth of AML Flashcards
What are the 5 Duties of an AML Analyst?
*(TICER)
- Transaction Monitoring
- Investigation
- Communication
- Examine
- Reporting
AML Analyst: Transaction Monitoring
Carefully investigate to see if the activity going on in an account relates to the KYC expected activities that has initially been submitted.
AML Analyst Level 1 should be monitoring the alert as far back as 6 months and should be noting any change in pattern of the account over time.
AML Analyst Duties: Investigation
Investigating and assessing the financial, operational and reputation risks posed by the customer through the alert generated.
AML Analyst Duties: Communication
Communicate your decision in a descriptive narrative with AML level 2, either you are closing the alert as non-issue or escalating for further review.
How AML Analyst 1 will know when to communicate for further review:
1. If you can mitigate the risk attached to the alert, then close it as a non-issue
2. If you cannot mitigate the risk attached to the alert, then send to AML 2 for further review.
AML Analyst Duties: Examine
CASE LEVEL
AML level 2 Analyst then re-examines data and information provided to verify all AML regulations are met before filing SAR
AML Analyst Duties: Reporting
AML Analyst 2 has 2 options.
1. If you are able to mitigate risk, then close as: non-issue
2. If you not able to mitigate risk, then file Suspicious Activity Report (SAR)
• Report information that illustrates the overall performance of the alert to the regulatory authorities
• FINCEN
3 major questions AML Analyst Investigation must answer
(*SUR)
- Source of funds
- Usage and purpose of the funds
- The relationship between the customer and the counter party
At which point in the AML process does the QA/QC Analyst perform their duties?
- The QA/QC Analyst engage the the process after the communication stage with AML Analyst and AML analyst 2 has taken place. The QA/QC must review the alert before it can be forwarded to AML analyst 2 for the Examining stage.
- The QA/QC Analyst will also verify the performance of AML analyst 2 after the reporting stage based on checklist used to review performance.
• The QA/QC analyst uses a checklist and scores AML analyst 1 and 2 based on each category for performance ratings.
Alerted Activity
The activity or transaction that triggered the alert.
• Alerted activity is not in line with usual accounting activities
Suspicious Activity
Activity in an account are out of the norm or a to that has never happened before.
• Every alerted activity is a suspicious activity
Change in Behavior
When something changes in an account so an alert is triggered or when an account goes out of normalcy.
Manual Alert
When the cashier or teller notices anything suspicious, they will report it to the financial manager or bank manager about the unusual activity.
Systematic Alert/ Automated Alert
Automatic Monitoring System (AMS) is employed within the systematic alert and will be triggered when activities are not in line with the what customer provided at KYC level, or when a wire comes in from a sanctioned country or when large sums of funds are transferred in and out of the account.
What are the 3 factors that trigger an alert
(*VVG)
- Volume: large sums of fund enter the account
- Velocity: the rate at which the funds are being transferred in and out of the accounts
- Geography: High transaction activities involving high risk countries such as Nigeria, Sudan, China, Russia Etc.
SAR Level
The information gathered during the investigation will be inputted into the SAR form and then submitted to law enforcement
Page 1. Customer personal information
Page 2. The type of alert triggered
Page 3. Due diligence
Page 4. The reason for submitting the SAR form
