sebbi.proBankingLaw mapChecksSystem
sebbi BANKING · 40 checks

Forty banking fraud controls, checked and sealed

Send your controls record and get every result back with a receipt sealed into the chain. Firms already sending signals pass BK40 by themselves.

curl -X POST https://sebbi.pro/x/banking/assess -H 'Content-Type: application/json' \
  -d '{"record": {"cop_enabled": "true", "cop_mismatch_action_recorded": "true", "monitoring_uses_onboarding": "true", "behaviour_monitoring": "true", "new_payee_high_value_rule": "true", "beneficiary_pattern_monitoring": "true", "alert_outcome_recorded": "true", "alert_sla_hours": "text", "intervention_playbook": "true", "inbound_mule_monitoring": "true", "linked_account_review": "true", "fraud_intel_sharing": "t ...}'
BK01Confirmation of Payee runs on every new payee
PSR SD17 / FCG · field cop_enabled
BK02Negative CoP results lead to a recorded intervention
FCA CP26/38 · field cop_mismatch_action_recorded
BK03Monitoring uses the expected activity captured at onboarding
FCA CP26/38 · field monitoring_uses_onboarding
BK04Payments that depart from expected behaviour are flagged
FCA CP26/38 · field behaviour_monitoring
BK05New payee taking a high value triggers review
FCA CP26/38 · field new_payee_high_value_rule
BK06Unusual values and beneficiary patterns are monitored
FCA CP26/38 · field beneficiary_pattern_monitoring
BK07Every alert ends in a recorded decision by a named role
FCA CP26/38 · field alert_outcome_recorded
BK08Alerts have a target time to respond
FCA CP26/38 · field alert_sla_hours
BK09Investigation and intervention steps are written down
FCA CP26/38 · field intervention_playbook
BK10Inbound mule monitoring on the receiving side
FCA mule review · field inbound_mule_monitoring
BK11Linked accounts considered in mule decisions
FCA mule review · field linked_account_review
BK12Fraud intelligence shared and used
ECCTA 2023 / FCG · field fraud_intel_sharing
BK13Controls reviewed against emerging fraud patterns
FCG · field control_review_date
BK14Policy for delaying payments on reasonable grounds to suspect
PSRs 2017 (2024 amendment) · field delay_policy
BK15Customer told of a delay, why, and what is needed
PSRs 2017 (2024 amendment) · field delay_customer_notice
BK16APP claims decided within 5 business days (35 with stop-the-clock)
PSR SD20 · field app_claim_sla_tracked
BK17Vulnerable customers exempt from excess and caution exception
PSR SD20 · field app_vulnerability_process
BK18Evidence kept for every gross-negligence finding
PSR SD20 · field app_exception_evidence
BK19Receiving-firm 50% repayment process in place
PSR SD20 · field app_receiving_process
BK20Foreseeable fraud harm assessed
Consumer Duty PRIN 2A · field fraud_harm_assessment
BK21Scam warnings tailored and tested for understanding
Consumer Duty PRIN 2A · field warnings_tested
BK22Vulnerability considered in fraud decisions
FCA FG21/1 · field vulnerability_in_fraud
BK23Firm-wide money laundering risk assessment
MLRs 2017 reg 18 · field firm_risk_assessment
BK24AML policies, controls and procedures
MLRs 2017 reg 19 · field aml_policies
BK25Ongoing monitoring of business relationships
MLRs 2017 reg 28(11) · field ongoing_monitoring
BK26Enhanced due diligence triggers defined
MLRs 2017 reg 33 · field edd_triggers
BK27Records kept at least 5 years
MLRs 2017 reg 40 · field record_retention_years
BK28Suspicion reported to the nominated officer and NCA
POCA 2002 s330 · field sar_process
BK29Money laundering reporting officer named
MLRs 2017 reg 21 / SYSC · field mlro_named
BK30Systems and controls against financial crime
SYSC 6.1.1R · field fincrime_controls
BK31Senior manager accountable for fraud
SMCR · field fraud_smf
BK32Fraud risk assessment for the failure to prevent fraud offence
ECCTA 2023 s199 · field fraud_risk_assessment
BK33Reasonable fraud prevention procedures (six principles)
ECCTA 2023 s199 · field fraud_prevention_procedures
BK34Staff trained on fraud prevention
ECCTA 2023 s199 · field fraud_training
BK35Fraud models in the model inventory and validated
PRA SS1/23 · field fraud_models_inventoried
BK36Fraud model performance monitored
PRA SS1/23 · field fraud_model_monitoring
BK37Verification of Payee on euro transfers
EU Instant Payments Regulation · field vop_enabled
BK38Transaction monitoring ready for EU liability rules
EU Payment Services Regulation · field eu_tm_ready
BK39Due diligence and monitoring mapped to the EU rulebook
EU AMLR 2024/1624 · field eu_amlr_mapped
BK40Fraud alerts and responses kept in a tamper-evident record
FCA CP26/38 / ECCTA · field tamper_evident_log
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