Metro 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

Customer Due Diligence

At sign-up the firm checks the applicant is a real, unique person using their genuine identity and device, blocking fake, stolen and bulk-created accounts before they open.

Starting threshold:

Decline on failed identity verification or failed liveness; route to manual review when the fraud score is in the top 5 percent or when 3 or more applications in 24 hours share a device fingerprint, residential address or funding instrument.

First-line owner:

Onboarding / Fraud Operations team

Ongoing Monitoring

The firm regularly proves that every account and every payment is actually being watched by its monitoring system, so nothing slips through an un-monitored gap.

Starting threshold:

Daily transaction-count reconciliation with a 0.1 percent variance tolerance; weekly full account-population reconciliation; zero tolerance for any account, product line or payment channel with no mapped monitoring scenario.

First-line owner:

Financial Crime Systems / Monitoring Operations team

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