Transaction Monitoring Tasks
Transaction Monitoring Tasks
Guavapay Monitoring System (GMS) Triggers:
GMS have a list of rules (see below) and scenarios that we have tailored in order to accurately monitor our customer’s transactional activity and hold payments (where necessary).
Online rule vs Offline rule:
Online rules will trigger an “AML control” status on Corebank and the payment will be held until the alert is fully completed and closed by an analyst. Online rules must be picked up and reviewed within 15 minutes. This does not mean that the alert needs to be closed within 15 minutes as some triggers may need longer investigate, for example if RFI is needed then the alert will not be closed, but the relevant status will then be selected (see below for further information of the statuses)
Offline rules flag the payment for retrospective review but does not hold the payment.
***When reviewing any payment/trigger we must always follow these steps***
Working An ONLINE Trigger
1. Login to GMS and select the 'Incidents' tab at the top. This will show you a list of open incidents that occurred in the last 24hrs.
2. Under current incidents you can add/remove filters to locate payments relating to a particular type or for a specific scenario (see 'Filtering Alerts' for more information)
3. Assign the new task to yourself. You can assign a task to yourself by clicking on the payment, then click on the incident and finally edit incident. Under owner you can search your name and assign to yourself. The status will also change automatically to 'work in progress'.
4. Once you've assigned this alert to yourself, you will take ownership of it. This includes reviewing and requesting further information if needed and closing the alert. If an investigation is required due to the outcome of the review then please see the 'Investigation' page.
5. When requesting RFIs (request further information) the task status must be either 'Awaiting RFI' for direct clients and 'Work in Progress' for sub-clients (relevant comments must be added to the comments).
6. i) When the status 'Awaiting RFI' is selected, an email is automatically sent to the client using your notes on the comments section. Add your initials to the final comment so you are able to search the email inbox for the sent RFI email.
ii) When working a sub-client, the status "Fraud. Review" is selected and an email is manually sent to our client for them to request the information from the sub-client. Please remember to leave a note on the comment section that an RFI has been sent to the client and what information has been requested.
⛔Please ensure your notes do not contain any information that may be seen as 'Tipping Off'⛔
7. i) Upon receiving satisfactory answer to our RFIs, we can clear the transaction by choosing status "Closed. False alert" & select "False alert" tag, and leaving a note in comment that documents or information requested has been provided.
ii) If the customer is not willing to provide the requested information or documents, or the provided reply is not satisfactory we reject this transaction by asking operations team and upon their confirmation we can close the task by choosing status "Closed. Fraud" & select tag "Fraud", and leaving a note in comment that documents or information requested has not been provided.
⚠️The note must include details of why you were able to arrive to the conclusion you did, as the same alert may be triggered again in the future and another analyst may need this information for new investigation.⚠️
Example: If the trigger is related to a Dow Jones check, do not write "Statement checked, regular activity."
Recommendation: Closure comments must directly reflect the nature of the triggered rule and address its specific requirements.
8. In some cases, we request RFI retrospectively, e.g. when the customer completes a type of transaction for the first time, such as their first international payment, we clear the transaction by choosing status "Closed. False alert" and select"False alert" tag, however we leave a note on the comment section that RFI has been sent retrospectively.
9. Provided information or documents for the requested RFIs must be saved in the Client Docs folder.
10. Remember to check/review any previously assigned tasks under your name which can be found under the 'Owner' filter. This can be done daily just to ensure no tasks are left unactioned.
11. Remember to check the email inbox payments@guavapay.com for any new responses for the RFIs requested
❗❗❗❗Once the customer responds to an RFI, appropriate actions must be taken without delay.
If the responsible analyst is unavailable, another team member should take over the case.
For high-priority cases or those involving large amounts, escalate the matter to the RFI creator or the relevant manager.
After the transaction is either approved or rejected, ensure the customer is informed accordingly. ❗❗❗❗
Working an OFFLINE Trigger:
For Offline Alerts, the transaction has already been completed, however, we may need to review and request further information to confirm the customer's activity is in line with our policies.
For offline triggers, nothing changes apart from the status selected and how we contact the customer. The offline trigger will appear on the same queue as the ONLINE trigger queue, therefore you can follow steps 1-4 then apply the below steps.
If there are no concerns around the activity then the status 'Closed. Analyzed' is selected.
If you need to send an RFI then you will need to select the status 'Fraud Review' and then manually email the customer.
Then continue with steps 9-11 above to complete the task.
As investigators, we trust you to use your skills and good judgment to confidently review investigations. If you're ever unsure, please escalate to a senior member in your team 😀
Canadian Clients
Follow the same steps as above, however, the escalation channels are different.
For alerts that you are unable to close and need further review then this needs to be escalated to Salvatore Bertucci
Filtering the alerts:
Main filters include:
Owner – This will filter alerts by the assigned analyst owner. When selected it will only show alerts under that particular analyst.
Rule – This will filter alerts by the transaction monitoring rule.
Status – This will filter alerts by the status of the payment e.g. opened, closed, work in progress etc.
Additional Filters:
Priority – This will filter alerts by priority (priority is determined by the system internally).
Channel Type – this will filter alerts by client type (individual or corporate) and offline or online (retrospective review or live review).
Other ways to search:
i) Event ID: To locate a specific payment then use the Event ID feature and enter the payment number. This can be found in Corebank under the #ID column.
ii) Client ID: This can help you locate all payments for a particular client. The client can be found by name or CIF number.
🔑For case examples please see this presensation that was prepared by our Analyst Elnura🔑