The only thing I would add is that, like my colleagues, we have very much the same process. I would like to emphasize how you flag this sort of activity. I put it in two large categories: it's people and it's systems. We train our front-line staff, our relationship managers, and people who interact with customers to be attuned to behaviour, actions, and transactions that don't make sense. They then escalate those up to an FIU, which is a team under the compliance function, which then investigates matters. We employ former law enforcement, etc. We use a system that monitors account activity for specified types of rules to see if people are behaving outside of those rules, which may suggest something unusual. That is then escalated through the system and further investigated. Those two processes help us identify behaviour.
On March 21st, 2013. See this statement in context.