AML Operations

An alert can be generated for multiple reasons such as:


  • Anomalous activity due to structuring, transactions occurring in unusual amounts or sudden burst of activity in the account, etc.
  • Profile deviation from past transaction activity due to unexpected transactions relative to stated/anticipated activity
  • Anomalous relationships or hidden relationships due to transactions or account activity with high-risk beneficiaries, originators or jurisdictions.

CRISIL GR&A alert investigators provide support across all levels:


L1 alerts: Rapidly identifying and validating an alert, checking whether the alert can be mitigated quickly or establishing that the alert is “true” and requires a detailed investigation


L2 alerts: Reviewing and validating alerts sent by L1 team. Based on the alerts, L2 investigators create a case to determine the nature of alert activity (such as anomalous activity, high risk transfer, etc.) and verify whether to report the activity to MLROs for SAR filing or close the alert. The activities undertaken during case creation will encompass a holistic investigation of the customer, transaction activity as well as other involved entities.


L3 alerts: Reviewing the cases from L2 investigators and validate their findings. After ensuring that the cases are accurate and compliant, they will report to MLROs to raise the Suspicious Activity Reports (SARs) or Unusual Activity Reports (UARs). They also interact with other regulatory officials in validating the investigation process for the alerted transactions/activities.




Case Study


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