Screening and transaction monitoring systems are the technical backbone of any effective AML/CFT compliance — and, at the same time, a central focus of BaFin audits. However, whether the systems in use are actually configured in a risk-adequate manner and whether downstream processes meet regulatory expectations can only be reliably answered through a structured, independent evaluation. WCTS audits screening and monitoring setups holistically: from system configuration to the operational processing of alerts.
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High false-positive rates, unclear thresholds or uncertainty in assessing individual alerts and business relationships are common practical signs that a screening or monitoring setup no longer aligns with the risk profile or regulatory expectations. An assessment brings clarity here at both the system and process levels.
The review covers the following areas:
Handling of internal reports and alerts in monitoring — technical and legal assessment of suspicious transactions and business relationships, including the preparation of suspicious activity reports (SARs) for the FIU and the examination of sanctions-related issues
Configuration of tools in use — review of rule sets, scenarios, thresholds, list integrations and underlying data quality, supplemented by support during adjustments
Operational effectiveness — analysis of alert processing, documentation practices, coverage of relevant typologies and ongoing monitoring of existing business relationships
Procedures and policies — design or revision of internal guidelines as well as gap analyses to ensure compliance with applicable AML/CFT requirements, tailored to the business model and organizational setup
