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P2P Transaction Monitoring
A U.S. bank asked Guidepost to assess whether its AML transaction monitoring system adequately captured peer‑to‑peer (P2P) payments (Zelle, Cash App, Apple Pay, etc.). We mapped and analyzed P2P and Zelle coverage, verified upstream data feeding the transaction monitoring system, and sample‑tested investigations/SARs and training artifacts to align with industry AML typologies and regulatory expectations.
The client was concerned that their existing transaction monitoring system did not adequately target peer to peer services. Guidepost reviewed the client’s scenario roster to ensure that the bank’s high-risk products such as electronic fund transfers were covered. Within the scenarios that provided coverage of electronic fund transfers, we identified, mapped and analyzed the scenarios covering Zelle as well as scenarios that can monitor other vendor-based peer to peer activity (CashApp, Apple Pay, etc.). As part of the Zelle and peer to peer scenario analysis, we reviewed and helped ensure that roster of scenarios included industry standard AML typologies that would meet regulatory expectations. Additionally, as part of our analysis we identified and verified the data systems that fed the transaction monitoring system could provide appropriate transactional data for ongoing transaction monitoring and alert generation including peer to peer and Zelle transactions.
In addition to the scenario roster review, Guidepost also conducted sample testing of case investigations and SARs to validate that peer to peer, including Zelle, alerted transactional activity output, were included in both case investigations and SARs where appropriate. The sample testing sought to confirm that the peer to peer and Zelle transaction monitoring alerts were being adjudicated appropriately and that alerted peer to peer transactional activity, including Zelle, was well incorporated in both case investigations and SAR narratives. This also included a review of training to ensure it covered peer to peer scenarios.
MSU Institutional Assessment + RAMAGELLAN MonitorshipEmpire/Liberty Review