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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).

  • 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.

  1. An alert enters the queue and the work pool.
  2. Maker triages and investigates within 48 hours (default), and recommends.
  3. Checker confirms or dismisses within 24 hours (default).
  4. Compliance Officer investigates confirmed alerts and escalates to the committee.
  5. 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.

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.

  • 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.