Know your business and ongoing monitoring

Know your business

You need to ensure that you know enough about your client and your client’s normal activities to be able to recognise anything unusual about transactions or instructions.

Then, if you have a suspicion of money laundering or reasonable cause to be suspicious, you must report it to your organisation’s Money Laundering Reporting Officer (MLRO) or other appropriate person.

Ongoing monitoring

The obligation to remain aware and report a suspicion continues throughout the client relationship. This is known as “ongoing monitoring”. The intention is to help you stay alert to any unusual activity that may require a revision of your risk assessment.

For example, a transaction may be suspicious because it is inconsistent with the size or nature of the client’s normal business activities. On the other hand, a transaction which may seem suspicious to someone who does not understand the client’s business may not be suspicious if the client’s normal business activities are understood.