Transaction Monitoring System. 4. (a) Within 45 days of this Agreement, the Bank and the New York Branch shall jointly submit to the Supervisors an acceptable written plan, including a timetable, for the full installation, testing, and activation of improved transaction monitoring software appropriate for the customer accounts and transactions at the New York Branch. The plan also shall include a methodology and target date for determining that the transaction monitoring system is effective.
Transaction Monitoring System. 6. Within 45 days of this Agreement, SSC and the Bank shall jointly submit a written plan acceptable to the Supervisors, including a timetable, for the full installation, testing, and activation of an effective automated transaction monitoring system to reasonably ensure the identification and timely, accurate, and complete reporting by SSC, its nonbank subsidiaries, and the Bank, as applicable, of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious activity reporting laws and regulations. Transaction Review
Transaction Monitoring System. 5. Within 60 days of this Agreement, the Bank shall engage an independent third party acceptable to the Reserve Bank to: (i) validate the effectiveness of the Bank’s transaction monitoring system (“Transaction Monitoring System Validation”) and (ii) prepare a written report of findings, conclusions, and recommendations (the “Transaction Monitoring System Report”).
Transaction Monitoring System. 7. Within 60 days of this Agreement, the Bank shall submit a written plan to the Reserve Bank, including a timetable, for the full installation, testing, and activation of an effective automated transaction monitoring system to reasonably ensure the identification and timely, accurate, and complete reporting by the Bank of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious activity reporting laws and regulations. Transaction Review
Transaction Monitoring System. The Broker may perform OFAC checks through the NASD website for purposes of detecting names of OFAC prohibited individuals, entities in countries and other adverse information about the customer ("negative verification").
