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Transaction monitoring

For non-banking industries, AML regulations impose less stringent requirements on transaction monitoring compared to banking industries, but there are still the following basic requirements:

  1. Understand normal business transaction patterns and establish transaction monitoring procedures to detect abnormal transactions.

  2. Conduct further investigation on transactions that exceed general business patterns or are of high risk, and identify suspicious transactions.

  3. Conduct regular or irregular monitoring and sample checks on the transaction details of some high-risk customers.

  4. Monitor large or abnormal transactions to understand their purposes and fund flows.

  5. Keep sufficient transaction records available for inspection by law enforcement and customs.

  6. Take interim actions such as suspending transactions against suspicious transaction customers and report to customs.

  7. Continually manage and update transaction monitoring mechanisms to adapt to business and money laundering risks changes.

  8. Assign compliance staff to be responsible for executing and checking the monitoring processes.

While the above requirements are less stringent than banks, they still require non-banking industries to implement basic transaction oversight to help identify suspicious activities. The actual level of implementation may vary across industries and products.

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