Transaction Monitoring

What is 'Smurfing' in transaction monitoring?

Smurfing is splitting a large sum into multiple smaller transactions to stay below the regulatory reporting threshold.

Does the National Bank check the monitoring software?

Yes, during NBG inspections, regulators evaluate whether the software is properly configured to detect high-risk activities.

How can I reduce 'False Positive' alerts?

Tuning thresholds and incorporating client behavior historical data can significantly reduce false positives and lower costs.

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Transaction Monitoring is the cornerstone of any modern financial organization's security in Georgia. It is the process of real-time or periodic analysis of monetary operations to determine their consistency with a client's profile and to detect potential illicit actions. The Georgian financial market is increasingly integrating into global systems, which elevates the importance of transaction monitoring. Regulatory bodies, such as the National Bank of Georgia, strictly require the existence of effective monitoring systems capable of preventing not only money laundering but also terrorism financing and attempts to circumvent sanctions. The Legal.ge platform provides information on experienced lawyers and compliance experts who will help you select and implement the optimal monitoring mechanisms for your business.

What does the Transaction Monitoring service cover?

Consulting and legal services related to transaction monitoring focus on protecting the organization from financial and legal risks. The service includes: developing internal monitoring policies based on "Know Your Customer" (KYC) principles; selecting and configuring automated transaction screening systems; defining suspicious operation typologies considering the specifics of your business; setting up the process for documenting and reporting monitoring results; and internal audits to evaluate the effectiveness of the monitoring system. Specialists also provide assistance during the individual study of "high-risk" transactions and offer recommendations on their approval or rejection.

Common real-world scenarios

In practical activities, transaction monitoring often faces complex challenges. A typical scenario is the sudden activation of "dormant accounts" with large sums, which often points to illegal financial flows. A second scenario concerns a series of transactions that are individually small but in total exceed the reporting threshold (30,000 GEL). Monitoring operations involving virtual assets (cryptocurrency) and their conversion into traditional money is also important. There are frequent cases where a client carries out a transaction with a person who is indirectly connected to sanctioned countries or entities. In such cases, the participation of a professional lawyer is necessary to correctly classify the risk and avoid violating international sanctions.

Georgian Legal Framework

Legal regulation of transaction monitoring in Georgia is based on the Law of Georgia on Facilitating the Prevention of Money Laundering and Terrorism Financing. This law obliges obliged entities to carry out continuous monitoring of the client's activities. In addition, the Order of the President of the National Bank of Georgia on Approving the Rule on Facilitating the Prevention of Money Laundering and Terrorism Financing by Financial Institutions is in effect. Instructions from the Financial Monitoring Service, containing specific signs of suspicion, are also important. The legislation provides that monitoring must be adequate for the risks the organization faces in its activity.

Step-by-step process when working with a specialist

Implementing or improving a monitoring system begins with creating a "risk map." In the first stage, the specialist studies the organization's client base and transaction types. In the second stage, monitoring parameters (Thresholds) are established. The third stage involves a testing mode where the accuracy of "alerts" recorded by the system is checked. In the fourth stage, training of Compliance Officers takes place so they can conduct high-quality investigations of suspicious cases. The process ends with the implementation of a continuous reporting system for monitoring results. The specialist ensures that the entire procedure is transparent and in compliance with the regulator's requirements.

Why choose Legal.ge?

Transaction monitoring is a field where technology and law intersect. On the Legal.ge platform, you have the opportunity to connect with experts who have practical experience in both setting up software systems and their legal validation. Our specialists will help you create a system that is not only law-compliant but also tailored to the interests of the business, minimizing the delay of legitimate transactions. Find your partner on Legal.ge and ensure the high reliability of your financial operations. Our platform offers quality service and a professional approach to tasks of any complexity.

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Specialists for this service

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