Transaction Monitoring
For a DA Dealer, CDD Core reads the trading feed from Trading Core and runs monitoring rules over it, alongside the on-chain risk results Trading Core receives. An alert is triaged by a maker and signed by a checker; it can open a review case, lead to EDD and restriction, and go to the committee as a possible STR.
Who may do it: the system raises alerts · Maker (triage) · Checker (confirm or dismiss) · Compliance Officer (investigate, escalate) · Head of Compliance (owns the triage times) · Internal Audit (read).
What is monitored (DA Dealer)
Section titled “What is monitored (DA Dealer)”- The trading feed — trades, deposits and transfers from Trading Core, by daily file or API.
- Rule set — structuring, layering, flows to and from high-risk countries, activity out of line with declared income and source of wealth, fast in-and-out flows, many funding accounts, high-value stablecoin churn, and activity tested against the declared purpose of the account. The rules follow the association’s guideline as the floor.
- Device and identity patterns — the device seen at account opening is compared with later activity.
- KYT results — on-chain risk results for each address and transfer, received from Trading Core and shown on the customer’s KYT tab.
A rule whose threshold the dealer has not yet set cannot be switched on.
- An alert enters the queue and the work pool.
- Maker triages and investigates within 48 hours (default), and recommends.
- Checker confirms or dismisses within 24 hours (default).
- Compliance Officer investigates confirmed alerts and escalates to the committee.
- The committee resolves; a resolution to report starts the STR clock.
An inconsistency between activity and what the customer declared opens a review case, which can lead to EDD and to restriction.
Fund business
Section titled “Fund business”A fund business works from the facts officers hold — letters from AMLO, screening results, restriction cases and their own findings — and the same committee path to an STR.
What the system does or refuses
Section titled “What the system does or refuses”- Breaches of triage times are flagged on the Head of Compliance’s and Internal Audit’s dashboards.
- Triage times run before the statutory clock and are not part of it.
- The elapsed time from alert to resolution is shown for every case.
- CDD Core does not call the on-chain analytics provider again; it uses the results Trading Core already holds.