TRANSACTION MONITORING

Course Syllabus
Audience
The primary target is the frontline analyst, teaching skills that benefit new and experienced
employees, especially as regulator and market expectations increase. This course assumes
the employer has already introduced that organization’s unique roles, processes, systems,
and common cases, and this course will not conflict with those. To bring all learners to a
shared baseline of terminology, concepts, and processes, the course starts with the “Essen-
tials” video and then builds from there.

The course is written and presented by subject matter experts working around the world. It
pulls examples from many countries, and is globally appropriate. The lessons and examples
are relevant to any industry. A primary focus is “financial institutions,” including banks, credit
unions, asset managers, insurance, MSB, securities broker-dealers, credit card issuers, alter-
nate payment systems, etc.

Course Structure
ACAMS allows you 4 calendar weeks to complete 4 hours of coursework, including a final
assessment. You will be guided using a learning path on ACAMS’ learning management
system (LMS). Follow carefully all instructions. Live virtual classroom events are pre-scheduled
before you purchase the course. 4 weeks from the course start date your access expires.

Assignment Format Download from LMS

Week 1 30 mins – VIDEO Video: Self-paced, available anytime PDF quick reference
“Essentials”

Week 2 90 mins – VIRTUAL Live event: See LMS for date/time. Afterward a PDF slides
CLASSROOM recording will be on the LMS.

Week 3 90 mins – VIRTUAL Live event: See LMS for date/time. Afterward a PDF slides
CLASSROOM recording will be on the LMS.

Week 4 15 mins – HOMEWORK Self-paced, available anytime PDF assignment

15 mins – ONLINE Self-paced, available anytime PDF ACAMS certificate

ASSESSMENT

To earn the certificate you must pass the assessment within the 4 weeks. The assessment has
20 questions. The minimum passing score is 80%. Multiple attempts are allowed. When you
pass, your ACAMS Certificate will be available in the learning path itself. Click to download a
PDF. ACAMS will automatically add 4 CAMS Credits to your profile to earn the certificate you
must pass the assessment within the 4 weeks.

© ACAMS. All rights reserved. Transaction Monitoring course syllabus

This information is subject to change. updated 05MAR2019 1
Technical Requirements:
The course is compatible with most operating systems and browsers to make it easy to
participate. The video, homework, and final assessment are mobile-friendly. The virtual
classroom uses Webex Event Center which currently does not support mobile devices.
The ACAMS Learning Management System (LMS) is www.lms.acams.org. Contact your
organization’s IT department for assistance.

© ACAMS. All rights reserved. Transaction Monitoring course

This information is subject to change. syllabus updated 05MAR2019 2
Behavioral outcomes of this course:
1. Recognize situations that would trigger alerts
2. Apply controls to monitor transaction activity
3. Detect unusual activity, generate alerts and investigate whether there is suspicious
activity
4. Continually refine alert thresholds to assure quality and continuous improvement

Course content
1. Introduction
a. The purpose of AML transaction monitoring is to provide ongoing identification of
unusual activity from customer transaction data
b. Process:
i. This is usually a three-stage process which includes:
1. Validate initial fundamentals of the alert (such as whether true cash is
involved or other factors which may impact the validity)
2. Escalate for initial investigate review
3. The SAR/no SAR decision is made based on a recommendation from
the previous step
c. Learning Objectives Overview: Upon completion of this learning experience, you will
be able to:
i. Recognize situations that would trigger alerts
ii. Apply controls to monitor transaction activity
iii. Detect unusual activity, generate alerts and investigate whether there is
suspicious activity
iv. Continually refine alert thresholds to assure quality and continuous
improvement
2. Recognize situations that would trigger alerts
a. Customer Types
i. Shell Companies
ii. Nonbank Financial Institutions (NBFIs)
1. Money Service Businesses
a. Dealer in foreign exchange
b. Check casher
c. Issuer or seller of travelers checks and money orders
d. Money Transmitter
e. Provider or seller of prepaid access

© ACAMS. All rights reserved. Transaction Monitoring course

This information is subject to change. syllabus updated 05MAR2019 3
 2. Brokers or dealers in securities
3. Finance / Loan companies
4. Financial Service Intermediaries such as Investment Advisors
5. Insurance Companies
6. Real Estate closing and settlement services
7. Casinos
8. Gaming Operations
9. Dealers in precious metals, stones, or jewels
10. Dealers in high value art
11. Dealers in planes, cars, and boats
12. Pawnbrokers
13. Travel agents
iii. Cash-Intensive small business
1. Vending companies
2. Car washes
3. Restaurants, taverns, bars, and nightclubs
4. Liquor stores, Off licenses
5. Laundromats/Launderettes
6. Taxi services and parking garages
7. Convenience stores
8. Gas stations, Auto Repair Garages
9. Cigarette distributors
10. Adult entertainment
11. Marijuana dispensaries, where legal in the US
iv. Vehicle Sellers
v. Trusts
vi. Professional Service Providers
vii. Charities / Non-Government Organizations
viii. Politically Exposed Persons (PEPs)
b. Countries
c. Products
i. Monetary Instruments
ii. Electronic Funds Payment Services
iii. Credit Cards
iv. Internet Banking

© ACAMS. All rights reserved. Transaction Monitoring course

This information is subject to change. syllabus updated 05MAR2019 4
 v. Prepaid Cards
vi. Private Banking
vii. Virtual Currency
viii. Trade Finance
ix. Foreign Correspondent Banking
x. Securities
xi. Insurance
d. Channels
e. Benefits of effective transaction monitoring
i. Personal
ii. Employer
iii. Society
3. Apply controls to monitor transaction activity
a. Create customer profile
i. Determine risk based on Customer Risk Rating Model
1. Develop criteria for monitoring (apply greater controls where risks are
higher)
2. KYC-CDD information (probably has already been established)
a. Nature and Purpose of business, source of funds
b. Expected transaction size, type, frequency
c. Recognize that a customer’s profile may change after becoming
a customer
i. Examples (Enhanced Due Diligence, EDD)
ii. Process for notifying/feedback to KYC-CDD department (KYC profile in
database would be updated electronically. Could be by many people—triage,
SAR, etc.)
b. Monitor transactions
i. Automated systems or manual
1. Automated systems are common for large organizations
ii. Need to know how to analyze and interpret regardless of the method
iii. Rules and thresholds
4. Detect unusual activity/generate alerts and investigate whether there is suspicious
activity
a. Activities that would generate an alert (alert to SAR ratio typically ranges from 2-8%.
AKA “conversion rate.”)
i. Sources of information/identification of unusual activity

© ACAMS. All rights reserved. Transaction Monitoring course

This information is subject to change. syllabus updated 05MAR2019 5
 1. Employee identified
2. Law Enforcement inquiries
3. Other referrals
4. Transaction and surveillance monitoring systems
ii. Be alert for any unusual activity
1. Analysts will rely more heavily on the source of the alert
2. With regard to high-risk customers
3. Transactions
4. Jurisdictions
iii. Is the account activity what we expected?
1. Need to understand the customer’s actual business
2. Need to understand the way the customer interacts with the financial institution
b. Clear alerts
i. Once cases are identified
ii. Before making a decision, it needs to be supported by a justification (based on the
known/gathered facts and an understanding of the risks involved)
c. Red Flags
i. Unusual patterns
ii. Unusual payments
1. Make business sense but are moving in the wrong direction
iii. Asset Movement (securities)
d. Investigate
i. Do the transactions make sense for the customer?
1. Some would get cleared right away based on the customer
a. Example: a wire transaction that exceeds the amount in their peer
group
b. OK to clear if it’s ordinary and expected
ii. 314B-Determine source of funds from another institution
iii. Do the transactions make sense based on the customer’s peers?

iv. Is there information to support a reasonable explanation for the activity?

v. Should the client be contacted for further information?
1. If so, who reaches out? Usually the Relationship Manager/branch manager who
has therelationship—not the TM team
2. Script for the relationship manager to use

© ACAMS. All rights reserved. Transaction Monitoring course

This information is subject to change. syllabus updated 05MAR2019 6
 3. What NOT to do
4. Non responses
5. Next steps
e. Report suspicious activity
i. SAR/STR
1. If suspicious activity cannot be ruled out
2. Process for completing a SAR/STR
3. Sign-off/accountability
f. Making the decision to close the account
i. When this is justified
ii. Who decides?
1. Individual
2. Committee
g. Scenarios: What would you do?
i. Clear alert
ii. Do more research
iii. Draft/Recommend a SAR
5. Continually refine alert thresholds to assure quality and continuous improvement
a. Common mistakes and how to avoid them
i. The importance of credible and reliable evidence
ii. Investigator needs to be able to provide rationale for the behavior/activity, or
iii. Escalate to the appropriate person(s)
b. Testing and Evaluation of TM
i. How to tune
ii. What documentation do you need for tuning?
iii. When should you tune (how often)
iv. Test environment

© ACAMS. All rights reserved. Transaction Monitoring course

This information is subject to change. syllabus updated 05MAR2019 7