MTD-STD-02 · Transaction Monitoring Standard (v2.3)

Identity, integrity & provenance

Document id

mtd-std-02

sha256 (the integrity anchor citations pin to)

1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce

Covers the extracted text, 1768 characters of it.

Added by

Demo User

Added at

2026-10-04 18:51 UTC

Source

register_document

Retain until

2032-10-04

Document control — provenance carried to the assessment stages as evidence metadata

Reference

MTD-STD-02

Version

2.3

Owner

Head of Financial Crime

Approved

Risk and Compliance Committee, 20 November 2025

Classification

Internal

Next review due

November 2026

Allocated to assessments

Where this document's content was filed at triage — 3 sections. A section can be allocated to more than one assessment. Change it with Triage and allocate, in the actions at the top of this page.

2.1 Monitoring universe and scenario coverage

2.1 All executed transactions, across Mittenda's payment services and crypto-asset services, are monitored against scenario-based rules calibrated to Mittenda's business-wide risk assessment. Scenarios cover, at a minimum: velocity and volume anomalies; structuring patterns; exposure to high-risk jurisdictions; and deviation from the expected activity established at onboarding.

EU 2023/1113 — Mittenda Limited

Mittenda Limited owns and performs transaction monitoring across its payment services and crypto-asset services, the PSP and CASP roles this assessment covers.

2.2 Alert disposition and reporting

2.2 Alerts are investigated and closed with a recorded rationale, or escalated in accordance with §5. Alert queues, ageing and disposition rates are reported under §6.

EU 2023/1113 — Mittenda Limited

Mittenda Limited investigates, closes or escalates its own monitoring alerts and reports alert metrics. The activity is the unit's own control.

2.3 Alert triage and ageing escalation

2.3 Alerts are triaged within two working days of creation. Alerts unresolved after ten working days are escalated to the Head of Financial Crime and reported monthly under §6.

EU 2023/1113 — Mittenda Limited

Mittenda Limited performs alert triage within set timelines and escalates aged alerts to its Head of Financial Crime. The unit owns this control.

Not allocated

Text no triage section covers — 5 passages. Often this is the title, document-control metadata or sign-off; if any of it belongs to an assessment, file it with Triage and allocate, in the actions at the top of this page.

# Mittenda Limited · Transaction Monitoring Standard (v

) · specimen excerpt > **Synthetic specimen.** Mittenda Limited is a fictional firm. This document is invented, > derived from scenarios seen in practice, and contains deliberate deficiencies for > demonstration. It is not a template and must not be adopted. **Document control:**

. | Version | Date | Change | |---|---|---| |

| November 2025 | Scenario thresholds recalibrated across both rails | | 2.2 | April 2025 | Crypto-asset rail scenarios added | *[Earlier versions omitted]* **Contents** 1. Purpose 2. **Monitoring universe** 3. Scenarios and calibration 4. Alert investigation 5. Escalation and reporting 6. Governance Appendix A: Scenario library *Sections in bold are excerpted below.* *[Section 1 omitted]* ## 2. Monitoring universe

*[Sections 3 onward and Appendix A omitted]*

Document text

1768 chars

Mittenda Limited · Transaction Monitoring Standard (v2.3) · specimen excerpt

Synthetic specimen. Mittenda Limited is a fictional firm. This document is invented, derived from scenarios seen in practice, and contains deliberate deficiencies for demonstration. It is not a template and must not be adopted.

Document control: MTD-STD-02 · owner: Head of Financial Crime · approved: Risk and Compliance Committee, 20 November 2025 · classification: Internal · next review due: November 2026.

Version	Date	Change
2.3	November 2025	Scenario thresholds recalibrated across both rails
2.2	April 2025	Crypto-asset rail scenarios added

[Earlier versions omitted]

Contents

Purpose
Monitoring universe
Scenarios and calibration
Alert investigation
Escalation and reporting
Governance

Appendix A: Scenario library

Sections in bold are excerpted below.

[Section 1 omitted]

2. Monitoring universe

2.1 All executed transactions, across Mittenda's payment services and crypto-asset services, are monitored against scenario-based rules calibrated to Mittenda's business-wide risk assessment. Scenarios cover, at a minimum: velocity and volume anomalies; structuring patterns; exposure to high-risk jurisdictions; and deviation from the expected activity established at onboarding.

2.2 Alerts are investigated and closed with a recorded rationale, or escalated in accordance with §5. Alert queues, ageing and disposition rates are reported under §6.

2.3 Alerts are triaged within two working days of creation. Alerts unresolved after ten working days are escalated to the Head of Financial Crime and reported monthly under §6.

[Sections 3 onward and Appendix A omitted]

What it evidences

Controls (12):Service-level latency for rejection flagging Pipeline ordering enforcing pre-processing admissibility detection Refusal decision gating Monitoring risk-factor selection policy During- vs after-transfer monitoring allocation criteria Per-transfer admissibility audit trail retention Flagged missing-information review queue routing and working Periodic refresh of detection criteria against risk assessment Admissibility-detection defect metrics dashboard Verification defect metrics dashboard Missing-information detection defect-metrics monitoring Information-on-request intake recognition classifier

Obligations (35):Beneficiary PSP procedures to detect missing originator or beneficiary information Detect whether originator and beneficiary information accompanies inbound transfers Criteria for real-time versus post-transfer monitoring triggers Determination of travel-rule monitoring risk factors Policy for detecting transfers that appear to be linked Reasonable grounds for suspecting money laundering or terrorist financing Reduced information set for unlinked transfers up to EUR 1 000 Missing information as a factor in suspicion assessment Method for identifying threshold circumvention or evasion attempts Reasonable grounds for suspecting money laundering or terrorist financing Missing originator or beneficiary data as a suspicion and FIU-reporting factor No originator verification for low-value intra-Union transfers

12 of 35 shown

Cited by (50):

Cited by	Suggestion	Version	When
Mittenda Limited	Coverage Not evidenced — Information-on-request intake recognition classifier sg-0384	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Verification defect metrics dashboard sg-0368	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Missing-information detection defect-metrics monitoring sg-0369	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Admissibility-detection defect metrics dashboard sg-0349	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Periodic refresh of detection criteria against risk assessment sg-0339	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Flagged missing-information review queue routing and working sg-0336	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Per-transfer admissibility audit trail retention sg-0330	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — During- vs after-transfer monitoring allocation criteria sg-0327	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Monitoring risk-factor selection policy sg-0323	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Pipeline ordering enforcing pre-processing admissibility detection sg-0312	current — v1`sha256 1598ea3c2bf538ac9c174cedabf82d071536f390e86180f6aa8d8a291fb03dce`	2026-10-04 20:13

10 of 50 shown

Assistant findings

50 grounded in this document

What the assistant surfaced from this document — accept or reject them on the findings and coverage page.

Finding	Value	Confidence	Status
Head of Financial Crime (MLRO) sg-0004	Head of Financial Crime (MLRO)	High	Accepted
Risk and Compliance Committee sg-0006	Risk and Compliance Committee (group)	High	Accepted
Beneficiary PSP procedures to detect missing originator or beneficiary information sg-0032	Not evidenced	Medium	Accepted
Detect whether originator and beneficiary information accompanies inbound transfers sg-0070	Not evidenced	Medium	Accepted
Criteria for real-time versus post-transfer monitoring triggers sg-0078	Not evidenced	Medium	Accepted
Determination of travel-rule monitoring risk factors sg-0082	Not evidenced	Low	Accepted
Policy for detecting transfers that appear to be linked sg-0084	Not evidenced	Medium	Accepted
Reasonable grounds for suspecting money laundering or terrorist financing sg-0115	Not evidenced	Medium	Accepted
Reduced information set for unlinked transfers up to EUR 1 000 sg-0139	Partial	Medium	Accepted
Missing information as a factor in suspicion assessment sg-0140	Not evidenced	Medium	Accepted

10 of 50 shown

Audit timeline

Every event on this document (66)

When (UTC)	Actor	What	Change
2026-10-06 13:38:05	Demo User	Document viewed	"MTD-STD-02 · Transaction Monitoring Standard (v2.3)" opened on the register detail.
2026-10-06 13:38:05	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 10:10:57	Demo User	Document viewed	"MTD-STD-02 · Transaction Monitoring Standard (v2.3)" opened on the register detail.
2026-10-06 10:10:57	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 10:05:28	Demo User	Document viewed	"MTD-STD-02 · Transaction Monitoring Standard (v2.3)" opened on the register detail.
2026-10-06 10:05:28	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 08:53:37	Demo User	Document viewed	"MTD-STD-02 · Transaction Monitoring Standard (v2.3)" opened on the register detail.
2026-10-06 08:53:37	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-05 10:22:07	Demo User	Document viewed	"MTD-STD-02 · Transaction Monitoring Standard (v2.3)" opened on the register detail.
2026-10-05 10:22:07	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
15 of 66 shown