AML Report & Full Auditing

In practice, that means that FX firms should:

• Perform customer due diligence (CDD) checks at onboarding and throughout the customer relationship to verify customer identities accurately. CDD checks should also be used to establish beneficial ownership if dealing with another FX company.
• Implement transaction monitoring measures in order to spot suspicious FX transactions that might be indicative of suspicious activity. This includes transactions over certain reporting thresholds, unusual transaction patterns or transactions involving high-risk countries.
• Screen and monitor customers for the politically exposed person (PEP) and sanctions status and for their involvement in adverse media stories.
• Appoint a compliance officer to oversee the compliance program, liaise with financial authorities and manage audits.

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