Know Your Transaction: Boosting AML compliance with KYT
Know Your Transaction: Boosting AML compliance with KYT
We understand that KYC (Know Your Customer), the crucial aspect of AML compliance, identifies the customers with whom business transactions are executed. Similarly, there is a concept, “KYT” – Know Your Transaction, aimed at uncovering the details of the transaction proposed to be carried out with the customer, including assessing the risk associated with such transaction.
Once the regulated entities know the transactions and related details, they are better placed in their anti-money laundering efforts, detecting the potential red flags. So, let us understand what KYT (Know Your Transaction) is.
What is KYT?
Know Your Transaction is one of the risk mitigation measures, which involves collecting the critical details of the business transaction to understand it better, determine its consistency with the customer’s overall profile, and determine the involvement of money laundering (ML) or any other financial crime risk.
KYT completes the Customer Due Diligence process, helping the regulated entity establish the customer profile, including the customer risk assessment, as the transactional details do give information about the customer’s activities or at least validate the customer profile determined by the compliance team.
By analyzing the financial transactions, the regulated entity can determine suspicious activities and stop them. Based on the data points, the regulated entity can determine whether the transaction aligns with the customer’s usual activities or if something suspicious exists.
What is the need for KYT?
The regulated entities subject to the AML regime in UAE deploy KYC measures to identify the customers. This includes obtaining identification details like customers’ names, ultimate beneficial owners (UBOs) in case of corporate customers, addresses, contact details, and other relevant details to establish the customer’s identity. But merely with KYC, the regulated entity cannot develop a complete customer profile or assess the potential risk exposure until the entity understands the proposed transactions.
This is where KYT comes into action.
With KYC, the regulated entity can identify whether a customer is the one they claim to be or is a financial criminal with some negative background. If they are identified as a criminal or sanctioned, the regulated entity applies adequate controls or possibly does not transact with them. But where the customer’s identity has been established to be clear, the risk of such a person exploiting the business for money laundering or terrorism financing cannot be negated. Thus, it is crucial to assess the transaction and identify the transactional parameters and their consistency with the identification details furnished by the customer.
The significance of KYT has increased due to a rise in cryptocurrency transactions. Since these are anonymous and decentralized transactions, the ML threat is higher. So, knowing more about the transactions before undertaking them becomes critical. Besides, KYT is also necessary for electronic fund transfers, including cross-border transactions.
In this context and as mandated by UAE AML regulations, for financial institutions like banks and Virtual Asset Service Providers (VASPs), KYT is very crucial to decode the identity of the originator and the beneficiary involved in the fund transfer or the virtual asset transfer. Not just this, these regulated entities are required to transmit the message to the counterparty financial institution or the VASP, capturing the details of the originator (payer) or the beneficiary (payee), along with the fund or virtual asset transfer request (complying the requirement of FATF Travel Rule).
KYC helps identify the suspicion related to the person, but to spot the red flags in the proposed transaction, KYT is inevitable.
With adequately implemented KYT, the regulated entities can identify and assess the following aspects of a transaction:
- All details on involved parties (originator, beneficiary, their account or virtual asset wallet details)
- Geographies involved (including geo-location and IP address in case of electronic transfers)
- Amount of the transaction
- Date of transaction
Not restricted to one-time activity, KYT also refers to the ongoing monitoring of transactions. Thus, once the entity has all these details on a transaction, along with transaction history and the customer profile, it can identify patterns or trends in them. If something suspicious is detected, the regulated entity can investigate further for any ML/FT threat. Thus, KYT is essential to keep the business safe from financial crimes.
Now that we know why KYC is significant, let’s look at the tips that must be adopted to ensure a smooth KYT process.
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Tips to improve the KYT process
Besides KYC processes, KYT is essential for achieving AML compliance. Pay attention to the following tips and tricks to remove inaccuracies in KYT and leverage the benefit of KYT to foster the ML/FT guards:
Give it as much importance as KYC
We all know that KYC is a critical pillar of AML compliance. KYC enables the regulated entities to know the customers better. It helps to find out if any of the existing or potential customers have any potential links to money laundering or other criminal activities. However, these measures are incomplete and do not give a complete picture of the customer’s risk profile without knowing the transactions. Thus, KYT is an equally critical measure for AML compliance.
Understanding and investigating the transactions enables the regulated entity to know if they facilitate illegal activity. If not, the entity is suitable to move ahead with the transaction. If yes, the regulated entity can terminate or cancel the transaction. Thus, the business is saved from reputational damage and non-compliance penalties.
Use all data on transactions to analyze them
When applying the KYT measures, collect all information pertaining to the transaction. It includes parties to the transaction (originator of the transfer and the beneficiary/(ies)), date, value involved, geographic location, and other relevant information (like unique transaction reference number or transaction hash in case of virtual asset transfer).
The regulated entity cannot determine whether the transaction is suspicious based only on one factor. It must consider all the details to know the ins and outs of the transaction. The regulated entity can find its linkages with illegal activities or criminals by analyzing various transactional parameters. Thus, the regulated entity must assess all the aspects of a transaction, considering the outcome of the KYC and overall customer profile, to determine if it is suspicious.
Define rules to detect unusual trends or patterns
To detect any red flags or suspicions, the regulated entity must define specific rules or parameters to gauge each transaction, considering all the relevant transactional parameters. These rules include transactional patterns, frequencies, time gaps, beneficiaries involved, geographies associated with the transaction and the value. And when anything goes against these rules, there must be an alert.
Further, the rules must also be defined, factoring in the customer’s identification details and the overall risk profile. Thus, the regulated entity is immediately notified if any inconsistencies are observed between KYC and KYT.
Regulated entities can determine unusual patterns or trends based on these rules and algorithms. It can identify if a transaction’s execution deviates from the established norms. Such deviation, unusual activity, or uncertain behaviour are the aspects that make a transaction suspicious. Therefore, defining rules, parameters, or criteria is essential to monitor transactions.
Ensure data quality to reduce false positives
When transactional data quality is ensured, accurate results can be expected, and risk indicators can be spotted promptly. Obtaining quality data and maintaining it securely is challenging.
The regulated entity can invest in quality data management systems to maintain data quality. The regulated entities can also use quality and reliable KYT solutions to investigate transactions. With well-defined algorithms and rules, the possibility of false positives can be reduced significantly.
Another aspect that needs to be taken care of is ensuring data consistency. The data may be obtained from different sources in different formats and languages. So, engaging in data cleansing and standardization is crucial before assessment and pattern detection.
Align the KYT exercise with UAE AML regulations
The regulatory requirements for AML keep changing. As and when new risks erupt, authorities amend AML rules. Also, particular guidelines for different industry sectors exist under the AML regime, e.g., mandatory compliance with the FATF Travel Rule by the financial institutions and the VASPs.
So, the regulated entities must align the KYT process with these regulations. It must stay up-to-date with the latest amendments to incorporate them into the KYT rules. Such alignment ensures an effective KYT process and also smooth AML compliance.
Technology is the go-to place for KYT automation
Collecting many data points on each transaction is a daunting task. And then analyzing them to detect suspicious behaviour demands high-level analytical skills. Manual management of all these steps will lead the business to errors and misses.
So, the best option is to automate the KYT process. Select a suitable KYT solution from the market customized to the business goals and needs. Set up relevant rules and parameters in it. With such a customized solution, the regulated entity will not miss any data and ensure accuracy. Also, it will save time with the automated KYT process, driving efficiency and quality of results.
With the emergence of AI, the Internet of Things (IoT), Machine Learning, Natural Language Processing (NLP), and Robotic Process Automation (RPA), the future of KYT is bright. These technologies can make KYT processes faster, more accurate and more efficient. The regulated entity can quickly analyze vast volumes of data in real-time and identify patterns. Thus, it can improve the quality of results in less time and effort.
Train the employees on KYT processes
The employees must have the necessary skills in transactional data collection and assessment. Explain to them the importance of the KYT process for achieving AML compliance. Training the staff around the nitty-gritty of KYT is essential for an accurate and comprehensive process.
Only with proper training will they know how to review and examine transactional data. When using tools and technologies like AI or machine learning for the KYT process, the employees must be extensively trained and educated on using these systems.
Report the suspicious transactions to authorities
What if a transaction is identified as suspicious?
The same must be reported to the authorities – internal (Compliance Officer) and external (Financial Intelligence Unit). That is what KYT and transaction monitoring are for.
When a transaction is identified as illegitimate or facilitating money laundering, report it to the AML Compliance Officer. The Compliance Officer shall investigate it further or instruct the discontinuation of the business relationship with that customer. Also, make a report to the Financial Intelligence Unit.
Maintain data confidentiality and security
Like KYC, KYT involves collecting sensitive information on transactions. Using such sensitive data can lead to data protection and confidentiality concerns.
So, the entity must ensure data security and disallow its further use for other purposes. The customer and transactional information must be safeguarded in all possible ways. Data privacy regulations, data encryption, and secure technologies to keep data safe.
How can AML UAE help in nurturing your AML compliance efforts?
You know the best practices to adopt in your KYT process. If you do it yourself, adopt these tips to ensure quality and accurate results. AML UAE is here to design and help you deploy the best practices around KYT and manage the ML/FT risks.
We can assist you in detecting and configuring the right tools and systems to comply with KYT requirements.
Interested in learning about how AML UAE can help you with AML compliance?
Get on a consultation call with us.
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About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is a Chartered Accountant with more than 25+ years of experience in compliance management, Anti-Money Laundering, tax consultancy, risk management, accounting, system audits, IT consultancy, and digital marketing.
He has extensive knowledge of local and international Anti-Money Laundering rules and regulations. He helps companies with end-to-end AML compliance services, from understanding the AML business-specific risk to implementing the robust AML Compliance framework.