
You Do Not Need Transaction Monitoring Software. You Need Thirty Minutes a Month and a Record That You Spent Them.
Ongoing customer due diligence is the part of the regime that never finishes, and three months in it is the part most small firms have not started. AUSTRAC says monitoring can be manual, automated or both, and spells out what a manual routine looks like. Here is that routine for a small Tranche 2 firm: what to look for, when a client's risk rating and KYC information must be reviewed, and what to write down.










