2. Formal documentation regarding monitoring and reporting of suspicious
transactions should be established.
Findings:
During the review period, we noted the True Money has responsibility to handle any customer
claims including fraudulent claims.
For fraudulent protection, True Money has certain business rules defined and set in the system
and applied to the use of True Money e-wallet accounts:
• Money balance not exceeding 30,000 Baht/Account
• Total transactional value not exceeding 40,000 Baht/Day/Account
Or
Total transaction counts not exceeding 20 Times/Day/Account
However, the documentation (Procedural Manual and Work Instructions) regarding monitoring
and reporting of suspicions transactions to the Anti-Money Laundering Office has not yet been
explicitly and/or formally established.
Business Impact:
Lack of formal documentation of the business guidelines and procedures may lead to failure to
comply with the Anti-Money Laundering law in regards to the effectiveness of monitoring and
completeness of data reporting.
Recommendations for Implementation Priorities: High