Fluz Transactional Monitoring Process

The Fluz transaction monitoring is conducted in various ways. We use pre-transaction monitoring and post-event transaction monitoring, in other words transactions can be monitored both beforehand and afterwards.

Pre-transaction monitoring Pre-transaction monitoring is carried out before effecting the transaction, and mainly applies to situations of face-to-face contact between the customer and the Fluz employee. In the case of post-event transaction monitoring the transaction has already been carried out by Fluz and transaction monitoring occurs afterwards.
We stress that we should also have a pre-transaction monitoring process in place, with appropriate measures to detect unusual transactions when or preferably before they are conducted.

We believe pre-transaction monitoring, either as an automated or a manual process, can effectively contribute to the detection of unusual transactions as it is in this stage that actual customer contact takes place. As such, the front office has a substantial responsibility in detecting unusual transactions such as money laundering and terrorist financing. This is relevant when a clear profile of expected transactions is drawn up at the start of the customer relationship for monitoring purposes. This will allow the institution to detect unusual proposed transactions even before they are effected, and notify them to FIU-NL without delay.

Post-event transaction monitoring This guidance document describes the post-event transaction monitoring process, because we are primarily able, based on non-cash settlement of transactions, to detect money laundering and terrorist financing risks in this manner.

Customer due diligence is part of the transaction monitoring process. Customer due diligence provides Fluz with knowledge of its customers, including the purpose and intended nature of the business relationship with the customer. This knowledge enables Fluz to conduct risk based assessments to ascertain whether the transactions carried out have unusual patterns that could indicate money laundering or terrorist financing. Fluz must tailor its transaction monitoring to the type of customer, the type of services provided and the risk profile of the customer or customer segment. This means monitoring can have a different set-up for the various customer segments and products to which Fluz provides its services.

Fluz Transactional Monitoring Process

The Fluz transaction monitoring is conducted in various ways. We use pre-transaction monitoring and post-event transaction monitoring, in other words transactions can be monitored both beforehand and afterwards.

Pre-transaction monitoring Pre-transaction monitoring is carried out before effecting the transaction, and mainly applies to situations of face-to-face contact between the customer and the Fluz employee. In the case of post-event transaction monitoring the transaction has already been carried out by Fluz and transaction monitoring occurs afterwards.
We stress that we should also have a pre-transaction monitoring process in place, with appropriate measures to detect unusual transactions when or preferably before they are conducted.

We believe pre-transaction monitoring, either as an automated or a manual process, can effectively contribute to the detection of unusual transactions as it is in this stage that actual customer contact takes place. As such, the front office has a substantial responsibility in detecting unusual transactions such as money laundering and terrorist financing. This is relevant when a clear profile of expected transactions is drawn up at the start of the customer relationship for monitoring purposes. This will allow the institution to detect unusual proposed transactions even before they are effected, and notify them to FIU-NL without delay.

Post-event transaction monitoring This guidance document describes the post-event transaction monitoring process, because we are primarily able, based on non-cash settlement of transactions, to detect money laundering and terrorist financing risks in this manner.

Customer due diligence is part of the transaction monitoring process. Customer due diligence provides Fluz with knowledge of its customers, including the purpose and intended nature of the business relationship with the customer. This knowledge enables the Fluz to conduct risk based assessments to ascertain whether the transactions carried out have unusual patterns that could indicate money laundering or terrorist financing. Fluz must tailor its transaction monitoring to the type of customer, the type of services provided and the risk profile of the customer or customer segment. This means monitoring can have a different set-up for the various customer segments and products to which Fluz provides its services.

Fluz Fluz LLC • 16 West 45th Street 7th Floor • New York, NY 10036 • [email protected]

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