What is transaction monitoring in AML?

It is the systematic review of customer transactions — in real time or after the fact — to detect patterns that may indicate money laundering, fraud, terrorist financing, or sanctions evasion, and to generate the alerts that lead to suspicious activity reports.

When must a SAR be filed?

A bank must file a SAR within 30 calendar days of initially detecting facts that may warrant one. If no suspect has been identified, it may take up to 30 additional days, but never more than 60 calendar days after initial detection.

What is the CTR threshold?

Financial institutions must file a Currency Transaction Report for cash transactions totaling more than $10,000 by or on behalf of one person in a single business day, aggregating multiple transactions that together exceed the threshold.

What is trade-based money laundering?

It is the use of trade transactions to move or disguise illicit funds — for example, over- or under-invoicing goods, shipping less than invoiced, or mislabeling products. It is a key reason transaction monitoring matters to importers and exporters, not just banks. A monitoring program lives at the intersection of financial-crime compliance and international trade, where the same red flags can signal both laundering and sanctions exposure. Reidel Law Firm helps trade-facing businesses align their screening and compliance controls with their actual risk — talk to a trade compliance attorney about your program.

Transaction Monitoring: An AML Compliance Checklist

Transaction monitoring is the ongoing review of customer transactions to detect and report activity that may signal money laundering, terrorist financing, fraud, or sanctions evasion. It is the engine of a Bank Secrecy Act (BSA) / anti-money-laundering (AML) program: rules and analytics flag unusual activity, trained staff investigate the alerts, and the institution files the reports the law requires. A monitoring program that misses suspicious activity — or ge