It's both. I think one of my colleagues said that there is the front line and then there's after-the-fact monitoring. There are activities that occur at the time of the transaction that we may be aware of, that are red flags and may cause us to raise a suspicion. Those front-line folks then take what they have seen and put it in a report called an unusual transaction report. That goes into our financial intelligence unit, and then we investigate further and determine whether an STR, a suspicious transaction report, should be filed. We also have automated monitoring systems, and there are certain things that hit those thresholds, be they jurisdictional or the types and frequency and volume of activity that might come out of a particular account.
On March 21st, 2013. See this statement in context.