WEEK THREE Lesson Two
TRANSACTIONS MONITORING
30 DAY COMPLIANCE PLAN
MONITOR
TRANSACTIONS
✓ Assign account tags and risk categories
✓ “Machine fingerprint” – device ID, operational system, language
settings, IP, biometrics. The device used for registration is a useful data
point for future account takeover detection
✓ Flag linked accounts based on shared devices, shared IP, shared
addresses, shared beneficial owners, shared payments instruments,
shared transactional patterns
WEEK THREE All about Tech
VELOCITY RULES
‣ Set velocity rules (sudden volume increase, awakening of a dormant account,
transactions between high risk accounts, sudden withdrawal requests, unusual
login, payments to high risk destinations, mismatch between shipping address
and billing address, dispute rate spike…)
‣ Assess rules efficiency frequently
‣ Credit checks, recovery effort assessment
‣ Social media check (especially for credit risk assessments and PEPs)
‣ Identity theft, compromised credentials
30 DAYS COMPLIANCE PLAN
TRANSACTION MONITORING/FRAUD DETECTION TOOLS
kount.com
clarus.io
simility.com
pipl.com
siftscience.com
30 Day Compliance Plan
BLOCKCHAIN
TRACKING
‣ Risk-score is generated at a given point in time based on:
✓ Involvement in disguising techniques, e.g. “mixers”
✓ Connection to known “bad” addresses and if so, total % of volume
✓ Connection to known mining pools
✓ Receiving funds from known custodians or reputable crypto exchanges
✓ After the funds are withdrawn from your platform, where did they go?
WEEK THREE All about Tech
BLOCKCHAIN TRACKING
elliptic.co
chainalysis.com
30 Day Compliance Plan
YOUR ADMIN TOOL
‣ Develop a scalable Admin tool, including
case management, account history analytics
and communications log
‣ Account statuses: active, restricted, closed,
waiting for information, under review + any
account tiers or pricing levels
‣ Funds statuses: available, not allocated, risk
reserve, disputed
‣ Warnings, reminders and automatic
messages
30 Day Compliance Plan
INSIDER TRADING
PRICE MANIPULATION
‣ Tag PEPs, financial institutions and linked accounts especially where same
persons are involved with different entities
‣ Tag insider accounts, including those created for testing
‣ Track transaction concentration between the same or linked users and “wash-out”
trades
‣ Know and track your highest volume traders per day/week/month and per asset
class
‣ Detect and investigate trades with significant price deviations, unreasonable
losses or massive reversals and cancellations
WEEK THREE All about Tech
