HSBC Bank plc

Transaction Monitoring

Checks that the firm's monitoring rules actually cover the risks the firm faces, so no major money-laundering pattern is left with no rule watching for it.

Starting threshold:

Zero unmapped assessed risks and zero in-scope product/channel populations missing from TM data feeds; any single coverage gap is an exception requiring a remediation plan with an owner and date.

First-line owner:

TM / Detection Engineering Lead (scenario estate owner)

Transaction Monitoring

Regularly tests and adjusts monitoring rule settings so the firm catches real risk without drowning analysts in pointless alerts, with evidence for every change.

Starting threshold:

Trigger a tuning review for any scenario whose true-positive yield falls below 5% (over-alerting) or whose below-the-line sample shows any productive (SAR-worthy) activity in the just-missed band (under-alerting); each change requires simulated impact and documented sign-off.

First-line owner:

TM Optimisation / Detection Engineering Analyst

Governance & Reporting

People independent of the day-to-day teams regularly test whether financial crime controls actually work, so weaknesses are found internally before a regulator finds them.

Starting threshold:

A risk-based assurance plan covering all high-residual-risk controls at least annually (lower-risk controls on a multi-year rotation); sampling sized to a defensible confidence level; every finding rated, owned, dated and re-tested at closure; no high-severity finding closed without independent verification.

First-line owner:

Control owners (remediate findings); first-line QA where it performs in-line checking