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Post-transaction monitoring across the sample portfolio. Every movement is logged in its original currency with a GBP equivalent and compared to the customer expected-activity profile.
| Date | Customer | Direction | Original | GBP equivalent | Corridor | Profile comparison | Rule hit | Status |
|---|---|---|---|---|---|---|---|---|
| 2026-07-17 | QA Test Holdings Ltd 100006 | Out | USD 9,000 | £7,110 | United Kingdom to United Arab Emirates | Within expected activity (about 250,000GBP per month) | HighAccount takeover / payment redirect | Held |
| 2026-07-15 | Reportly Limited 100003 | Out | GBP 9,850 | £9,850 | UK to UK | Within expected activity | HighAccount takeover / payment redirect | Under review |
| 2026-07-12 | La Lucia LTD 100004 | In | GBP 6,000 | £6,000 | UK to UK | Follows a dormant period, above the expected value | MediumDormant-then-active | Under review |
| 2026-07-12 | Reportly Limited 100003 | In | GBP 15,000 | £15,000 | UK to UK | Above the expected single-transaction value | HighHigh-value single transaction | Held |
| 2026-07-11 | Staff Connect Resourcing Limited 100005 | Out | USD 2,000 | £1,580 | Hong Kong to Israel | Same-day sequence to Israel, below the single-transaction threshold | High24-hour aggregation / structuring | Held |
| 2026-07-11 | Staff Connect Resourcing Limited 100005 | Out | USD 2,000 | £1,580 | Hong Kong to Israel | Same-day sequence to Israel, below the single-transaction threshold | High24-hour aggregation / structuring | Held |
| 2026-07-11 | Staff Connect Resourcing Limited 100005 | Out | USD 2,000 | £1,580 | Hong Kong to Israel | Same-day sequence to Israel, below the single-transaction threshold | High24-hour aggregation / structuring | Held |
| 2026-07-11 | Staff Connect Resourcing Limited 100005 | Out | USD 2,000 | £1,580 | Hong Kong to Israel | Same-day sequence to Israel, below the single-transaction threshold | High24-hour aggregation / structuring | Held |
| 2026-07-11 | Staff Connect Resourcing Limited 100005 | Out | USD 2,000 | £1,580 | Hong Kong to Israel | Same-day sequence to Israel, below the single-transaction threshold | High24-hour aggregation / structuring | Held |
| 2026-07-11 | Staff Connect Resourcing Limited 100005 | Out | USD 2,000 | £1,580 | Hong Kong to Israel | Same-day sequence to Israel, below the single-transaction threshold | High24-hour aggregation / structuring | Held |
| 2026-07-11 | Staff Connect Resourcing Limited 100005 | Out | USD 2,000 | £1,580 | Hong Kong to Israel | Same-day sequence to Israel, below the single-transaction threshold | High24-hour aggregation / structuring | Held |
| 2026-07-11 | Staff Connect Resourcing Limited 100005 | Out | USD 2,000 | £1,580 | Hong Kong to Israel | Same-day sequence to Israel, below the single-transaction threshold | High24-hour aggregation / structuring | Held |
| 2026-07-07 | Netanel Adrai Pagima 100002 | In | GBP 1,500 | £1,500 | UK to UK | Within expected activity (about 1500.0 per month) | None | Posted |
| 2026-07-02 | David Lipson 100001 | In | AUD 10,000 | £5,200 | Australia to UK | Within expected activity (about 10,000AUD per month) | None | Posted |
| 2026-06-27 | Reportly Limited 100003 | In | GBP 4,000 | £4,000 | UK to UK | Within expected activity | None | Posted |
| 2026-06-07 | Netanel Adrai Pagima 100002 | In | GBP 1,500 | £1,500 | UK to UK | Within expected activity (about 1500.0 per month) | None | Posted |
| 2026-06-07 | Staff Connect Resourcing Limited 100005 | In | USD 5,000 | £3,950 | Hong Kong to Australia | Within expected activity (about 20,000USD per month) | None | Posted |
| 2026-06-02 | David Lipson 100001 | In | AUD 10,000 | £5,200 | Australia to UK | Within expected activity (about 10,000AUD per month) | None | Posted |
| 2026-05-28 | Reportly Limited 100003 | In | EUR 4,500 | £3,825 | UK to Israel | Within expected activity | None | Posted |
| 2026-05-08 | Netanel Adrai Pagima 100002 | In | GBP 1,500 | £1,500 | UK to UK | Within expected activity (about 1500.0 per month) | None | Posted |
| 2026-05-03 | David Lipson 100001 | In | AUD 10,000 | £5,200 | Australia to UK | Within expected activity (about 10,000AUD per month) | None | Posted |
| 2026-04-28 | Reportly Limited 100003 | In | GBP 4,000 | £4,000 | UK to UK | Within expected activity | None | Posted |
| 2026-04-08 | Netanel Adrai Pagima 100002 | In | GBP 1,500 | £1,500 | UK to UK | Within expected activity (about 1500.0 per month) | None | Posted |
| 2026-04-03 | David Lipson 100001 | In | AUD 10,000 | £5,200 | Australia to UK | Within expected activity (about 10,000AUD per month) | None | Posted |
| 2026-03-09 | Netanel Adrai Pagima 100002 | In | GBP 1,500 | £1,500 | UK to UK | Within expected activity (about 1500.0 per month) | None | Posted |
| 2026-02-17 | La Lucia LTD 100004 | In | GBP 900 | £900 | UK to UK | Within expected activity (about 6000GBP per month) | None | Posted |
| 2026-01-28 | La Lucia LTD 100004 | In | GBP 950 | £950 | UK to UK | Within expected activity (about 6000GBP per month) | None | Posted |
| 2026-01-08 | La Lucia LTD 100004 | In | GBP 900 | £900 | UK to UK | Within expected activity (about 6000GBP per month) | None | Posted |
| Rule | Description | Window | Threshold (GBP) | Severity | Routes to | Policy basis |
|---|---|---|---|---|---|---|
High-value single transaction R1 | Single transaction at or above the threshold. EFTR relevance. | Per transaction | High | Trevor Clein | onboarding_tm_procedure section 11; ra_pcp EFTR | |
24-hour aggregation / structuring R2 | Three or more transactions in 24 hours, each below GBP 10,000, totalling at or above the threshold. | 24h | High | Trevor Clein | onboarding_tm_procedure section 11 | |
7-day structuring R3 | Five or more transactions in 7 days, each below GBP 10,000, totalling at or above the threshold. | 168h | High | Trevor Clein | onboarding_tm_procedure section 11 | |
Velocity / rapid movement R4 | Cumulative value at or above the threshold within any rolling 24 hours. | 24h | Medium | Trevor Clein | onboarding_tm_procedure section 11 | |
Dormant-then-active R5 | No activity for 90 days then a transaction at or above the threshold. | Per transaction | Medium | Trevor Clein | onboarding_tm_procedure section 12 (trigger events) | |
Sanctions / PEP / adverse-media potential match R6 | Screening potential match. Funds held, immediate MLRO escalation, no release pending review. | Per transaction | Not applicable | High | Trevor Clein | sanctions section 8; screening_sof_sow |
Corridor / new-country mismatch R7 | Transaction to a corridor that is inconsistent with the customer expected activity profile. | Per transaction | Not applicable | Medium | Trevor Clein | onboarding_tm_procedure section 12 (trigger events) |
Account takeover / payment redirect R8 | Outbound payment to a newly changed beneficiary following a login or device anomaly, or an urgent out-of-pattern instruction. Fraud red flag; hold pending callback verification. | Per transaction | Not applicable | High | Trevor Clein | anti_fraud (red flags: account takeover, payment redirection, invoice and mandate fraud) |
The current monitoring rules are medium and high severity and route to Trevor Clein (MLRO); the first-line path to Asher Freed applies to lower-severity alerts. Held items are not released until an authorised reviewer decides on the alert queue, and there is no automatic release on a timeout. Adjusting a threshold above and selecting Run monitoring re-evaluates the current transactions.