On 11 April 2023, the Financial Intelligence Analysis Unit (the
"FIAU") published a comprehensive guidance note on the transaction monitoring
obligations of subject persons, specifically aimed at institutions
that process payments and similar transactions on behalf of
customers, including banks, electronic money (e-money)
institutions, payment service providers (PSPs), and merchant
acquiring companies.
The guidance note provides subject persons with an understanding
of the FIAU's expectations with respect to transaction
monitoring, addresses certain misconceptions and highlights common
transaction monitoring findings identified throughout enforcement
and follow-up processes.
The guidance note outlines, inter alia, several
non-exhaustive key components of an effective transaction
monitoring program, including: