The outcomes of the first PwC Europe, Middle East and Asia (EMEA) anti-money laundering. (AML) Survey carried out earlier this year bring into focus the evolution of AML-related risk and regulation and the effectiveness of the relevant controls. In this sense, respondents emphasised the importance of “upskilling”, “screening” and “transaction monitoring” as the key AML controls.
Concurrently, the FIAU carried out a thematic review examining the understanding and awareness of AML/CFT matters in the remote gaming sector. Its results, published just one month prior to the EMEA AML Survey findings, also emphasised the importance of ongoing monitoring in the remote gaming sector, including transaction scrutiny - being one of the key measures which helps identify and address any unusual or suspicious activities.
It is evident that transaction monitoring plays a fundamental role in ensuring AML/CFT compliance. So how effective are remote gaming operators (RGOs) being in their transaction monitoring, and how is related data influencing their AML/CFT controls?
Here is a reminder on the point highlighted in one of the FIAU’s guidelines on the effective implementation of transaction monitoring:
- Ensuring that customer information is up-to-date
- Scrutinising transaction activity
- Investigating the customer’s Source of Wealth/Funds (SoW/SoF)
- Adjusting monitoring activity based on the customer’s risk profile
Ensuring that customer information is up-to-date
It is important to maintain familiarity with customer data, whilst also ensuring that the same data is accurate and valid, by ascertaining that the information on hand is updated.
Scrutinising transaction activity
This entails flagging any unusual transactions - being any activity which does not align with the customer’s profile or expected business activity - whilst also obtaining additional information explaining the reasoning behind such transactions. This allows the RGO to better tailor their approach to ongoing monitoring practices and risk assessments to particular customers.
Investigating the customer’s Source of Wealth/Funds (SoW/SoF)
Tying together with anomalous transactions, verification of the customer’s SoW/SoF is crucial. This is especially necessary when handling high-risk scenarios, even if the level of business activity remains consistent. The results of this investigation may determine whether or not Enhanced Due Diligence is necessary in a particular customer’s respect.
Adjusting monitoring activity based on the customer’s risk profile
As ongoing monitoring is carried out, the risk level allocated to the customer may vary depending on the circumstances at hand. It is thus important to ensure that monitoring is carried out frequently and efficiently.
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