Purpose
Ensure unusual complexity, size or lack of apparent purpose receives enhanced attention and a documented reporting decision.
Normative
Bitkaya shall identify and give special attention to complex transactions, unusually large transactions and unusual transaction patterns that have no apparent economic or clear lawful purpose, investigate their background and rationale and document whether an FIU report is required.
Descriptive
This requirement operates alongside the objective and subjective indicators. A transaction that does not meet an objective threshold may still require reporting under the subjective indicator.
Source reference: MOT Article 11(3).
Assurance Assertions
- Monitoring scenarios and manual reviews cover complexity, size, patterns and economic purpose.
- Investigations document the available background and rationale.
- The reporting decision and reviewer are recorded.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Procedure: PROC-AML-004 Perform Transaction Monitoring and Alert Review
- Procedure: PROC-AML-005 Perform FIU Reporting and Case Escalation
- Control: CTRL-AML-004 Ensure Transaction Monitoring Alerts Are Reviewed
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from MOT Article 11(3).