Five Questions for Analysts to Consider When Conducting an AML Investigation

Bank analysts and anti-money laundering (AML)investigators reviewing customer transactions have an important, but often overwhelming, job. Banking professionals tasked with alert resolution, performing periodic reviews on high-risk accounts, and conducting investigations during a look-back transaction analysis consider myriad variables. Increasing budget constraints, deadlines, and volumes of information make it challenging for analysts to address all factors for each investigation. But failure to consider key factors could result in incomplete analyses, regulatory criticism, or other enforcement actions.

While not meant to be all-inclusive, to streamline the investigation process, consider five questions that are easy to remember with the acronym P.I.O.U.S. – Patterns, In, Out, Unusual, and Suspicious:

1. What patterns, if any, do you notice in the transaction
activity? (PATTERNS)

2. What is the ultimate source of the funds? (IN)

3. What is the ultimate destination of the funds?
(OUT)

4. Are there any unusual transactions? (UNUSUAL)

5. Does the activity rise to the level of suspicious?
(SUSPICIOUS)