Understanding Below-the-Line Testing:
* Below-the-line testing evaluates scenarios where alerts were not generated but could have been if the thresholds were set differently.
* This testing method focuses on identifying potential gaps in the detection model that might lead to missed alerts for suspicious activities.
Significance in AML/CFT Compliance:
* This type of test ensures the system's thresholds are not too restrictive, which could result in legitimate suspicious activities being overlooked.
* It provides insight into whether the system needs re-calibration to balance false positives and missed detections.
Process of Below-the-Line Testing:
* Data Sampling: Analyze transactions that fall just below the alert generation threshold.
* Scenario Analysis: Identify whether these transactions exhibit patterns consistent with suspicious activities.
* Model Adjustment: Adjust thresholds to optimize the trade-off between sensitivity and specificity.
Advanced CAMS-Audit Reference:
* CAMS-Audit guidelines detail below-the-line testing as an integral part of tuning and validating monitoring models. It ensures that monitoring systems align with risk appetite and operational realities.
* FATF guidance on dynamic model validation highlights the importance of continuous review and adaptation of thresholds to evolving typologies and risks.
Case Example and Regulatory Perspective:
* Advanced CAMS-Audit recommends below-the-line tests especially in high-risk sectors, ensuring robust detection mechanisms.
* Regulatory expectations, as per FATF and Basel guidelines, require proactive measures to address model gaps that below-the-line testing can identify.