Areas for improvement identified in transaction monitoring questionnaire
We have identified a number of areas where businesses can improve how they monitor their transactions, following our recent questionnaire.
In July, we asked 25 businesses to provide us with more information to enable us to understand the methods they use to monitor transactions, including their relevant systems and controls.
The business we reviewed included; fund services business, investment business and trust company business. We also captured lawyers, estate agents, casinos, and lenders.
Identified deficiencies
A number of deficiencies were highlighted by those surveyed relating to existing systems and controls, including:
- no routine transaction monitoring performed
- systems and controls did not require the findings from transaction monitoring reviews to be recorded
- backlogs in reviewing transactions or related processes
- deficiencies in the oversight of transaction monitoring processes
- matters in transaction monitoring policies and procedures that required addressing
- training in relation to transaction monitoring did not take account of Jersey requirements.
Identified good practice
There were two areas of best practice identified in approaches to scrutinising transactions and monitoring activity:
- 68% of respondents confirmed that once a transaction monitoring review had been undertaken, they required a second reviewer to sign off its completion
- 53% indicated that transaction monitoring methods were tested before going live.
Next steps
As a result of the findings from this questionnaire, follow-on supervisory engagement may take place where relevant.
In the feedback paper we have outlined steps businesses can take to improve their transaction monitoring, which we recommend businesses consider.