Monitoring of Transactions and Reporting

Monitoring of Transactions and Reporting

• 1. Regular monitoring of transactions is vital for ensuring effectiveness of the Anti Money Laundering procedures. This is possible only if we have an understanding of the normal activity of the client so that they can identity the deviant transactions/activities.
• 2. Any transaction of retail clients of value exceeding 10 lakhs should be reported to compliance department if its an irregular transaction, transaction is irregular (i) if the size of the order is not commensurate with client income level disclosed or if its more than his usual order size (ii) if the order is placed by dormant client i.e order placed by client after a period of 1 year from his/her last transaction.
• 3. Any transaction which does not make economic sense or is complex or unusually large should be immediately brought to the notice of respective head of department and compliance department.
• 4. Value of the transaction not in proportion with the Financial income declared by the client.
• 5. Any large acitivity in dormant account.
• 6. Further the compliance department should randomly examine a selection of transaction undertaken by clients to comment on their nature i.e whether they are in the suspicious transactions or not.
• 7. Any transaction/order which arises the suspicion of any employee should be diligently and immediately informed to compliance department.
• 8. All the persons who are debarred/warned by SEBI/Exchanges to access capital Market will be black listed clients or any client against whom firm has reported to authorities for alleged money laundering activities and the matter is still pending before or order is given against the client.
• 9. Alerts generated by monitoring the transactions will be forwarded to the Board and the board will decide it to report STR or not.