The KYT, or Know Your Transaction, provides a transactional perspective on the AML-CFT compliance framework. The KYC establishes the customer’s identity, profile, and risk level. The KYT then monitors the transactions carried out: amounts, frequency, counterparties, countries involved, instruments used, and behavioral anomalies.
At AP Solutions IO, transaction monitoring is not limited to issuing alerts. It is used to identify atypical transactions, understand weak signals, document decisions made, and retain actionable evidence in the event of an by theACPR or a request from TRACFIN.
Our technology is based on Glass Box augmented intelligence. Each alert is linked to clear criteria: rule applied, threshold triggered, risk scenario, client history, country, counterparty, or observed frequency.
KYT and KYC: Two Complementary Checks in Customer Relations
The KYC meets a primary requirement: identifying the person entering into a relationship with the institution. It covers customer verification, identification of the beneficial owner, risk profile analysis, and detection of politically exposed persons, reputational risks, , and screening against sanctions lists.
The KYT is triggered after the relationship has been established. It analyzes actual account flows and compares transactions against the customer’s known profile. An isolated transaction may appear consistent, but reveal an anomaly when viewed within thecontext of the customer relationship.
A transfer to a sensitive area is assessed differently depending on the reported activity, the length of the relationship, previous transactions, and the supporting documentation available. It is this cross-checking that makes continuous monitoring of transactions.
The compliance officers thus have a more reliable basis for analysis when assessing an alert, requesting additional information, closing a case, or preparing an internal escalation.
Detection scenarios: structuring, smurfing, round-tripping, and layering
A device KYT cannot rely on simple fixed thresholds. Money laundering schemes frequently rely on mechanisms of repetition, fragmentation, or the artificial circulation of funds. Monitoring must therefore cross-reference amounts, frequency, customer behavior, and applicable risk typologies.
Structuring involves breaking down transactions in order to stay within an internal or regulatory limit. smurfing involves a series of small transactions carried out by multiple individuals or different accounts. round-tripping involves circulating funds between different entities before returning them, in whole or in part, to the original issuer. Layering multiplies and layers transactions to make the economic origin of the funds more difficult to trace.
The behavioral disruption also requires careful analysis. A transaction may be considered atypical based on its amount, destination country, counterparty, payment method, or frequency. Any deviation from the customer’s usual patterns is then an indicator that needs to be assessed.
With AP Solutions IO, these scenarios can be configured according to your customer segments, products, geographic regions, and internal policies. Your teams retain control over the criteria. The technology handles high volumes, prioritizes alerts, and reduces false positives, without compromising compliance reasoning.
AML-CFT regulatory thresholds AML-CFT customer identification, suspicious transactions, and transaction splitting
The applicable regulatory threshold for AML-CFT must be interpreted strictly and in accordance with the nature of the transaction in question. Contrary to popular belief, there is no single threshold of €15,000, but rather several thresholds set forth in the Monetary and Financial Code depending on the type of activity or transaction.
The main applicable thresholds include the following:
- €1,000 for manual foreign exchange transactions;
- €1,000 for the purchase or sale of certain digital assets;
- €10,000 for certain transactions involving cash or electronic money;
- €15,000 for other one-time transactions, in accordance with Article R. 561-10 of the Monetary and Financial Code.
The primary purpose of these thresholds is to trigger the obligation to identify and verify the customer, including in the case of an occasional customer. They should not be confused with Article L. 561-15 of the Monetary and Financial Code regarding the reporting of suspicious activity to TRACFIN.
This distinction is crucial: a regulatory threshold never replaces the analysis of suspicious activity. A transaction below the regulatory thresholds may still warrant enhanced scrutiny if it reveals fragmentation, an attempt at concealment, inconsistencies with the customer’s profile, or atypical behavior.
Conversely, a transaction that exceeds a regulatory threshold does not automatically trigger a suspicious activity report. It must be analyzed based on several criteria: the source of the funds, the economic rationale, the history of the business relationship, the countries involved, the reported activity, and the overall consistency of the transaction.
It is also important to distinguish between these thresholds AML-CFT thresholds from the limits applicable to cash payments. In France, cash payments to a business are, in principle, limited in accordance with Article D. 112-3 of the Monetary and Financial Code to:
- €1,000 when the debtor is a tax resident in France;
- €15,000 when the debtor is not a tax resident of France.
AP-Monitoring links each alert to the factors that triggered it: amount, frequency, counterparty, country, client profile, history, internal rule, or risk scenario. Teams can then assess the transaction, document the review, and, if necessary, prepare a suspicious activity report to TRACFIN with a more comprehensive and better-documented file.
Real-time API integration: monitor data streams without slowing down operations
The transaction monitoring must be integrated into the existing information system. A standalone tool fragments controls, increases manual tasks, and weakens traceability.
Our solutions SaaS, interoperable via API, integrate into operational workflows: account opening, payments, transfers, periodic reviews, customer scoring, sanctions screening, and alert management. This ensures that controls are applied as close as possible to the execution of these processes.
Late detection limits the ability to respond, while excessive latency undermines the customer experience. Real-time processing enables earlier decision-making, with a clear record of the rule applied and the decision made.
At AP Solutions IO, the architecture remains open, multilingual, and no-code. Your teams can adjust detection rules, modify thresholds, integrate new typologies, and align controls with your risk map. Hosting in France meets the requirements of the GDPR, while strengthening sovereignty and control over sensitive data.
AP-Monitoring: Making Transaction Monitoring Actionable for Auditing
AP-Monitoring is the solution AP Solutions IO dedicated to continuous transaction monitoring. It links financial flows, customer profiles, and risk scenarios in an environment designed for the day-to-day work of compliance officers.
The solution analyzes more than 90 configurable criteria and can reduce up to 98% of false positives, depending on the deployment context and the rules applied. This performance retains its full value thanks to a fully explainable logic. The Glass Box logic retains the parameters used, the trigger criteria, and the justification elements associated with each alert.
Continued AP Solutions IO works in modules:
- AP-Scan covers AML screening ;
- AP-Scoring structures customer profiling and AML-CFT risk assessment AML-CFT
- AP-Monitoring provides continuous monitoring of transactions/operations;
- AP-Filter applies flow controls in accordance with international sanctions and embargoes.
For teams, the benefits are immediate: fewer unnecessary alerts, more precise prioritization, and a clearer audit trail. For the compliance management, the requirement also extends to defending the system: justified rules, documented decisions, and evidence available in the event of an audit.
Transaction monitoring tailored to ACPR and TRACFIN audits
An effective KYT system must not only detect anomalies but also provide actionable insights for compliance teams. Compliance officers need to understand why a transaction was flagged, how it was handled, and what decision was made.
During an inspection, the authorities expect a system that is proportionate to the risks, properly documented, and consistent with AML-CFT risk assessment. Technology supports legal and regulatory analysis, without ever replacing human judgment.
With AP Solutions IO, you retain a complete record: configured rules, applied thresholds, affected profiles, analysis history, internal decisions, and information forwarded in the event of an escalation. Updates performed every four months, combined with integrated regulatory monitoring, help ensure the system remains effective over the long term.
FAQ — KYT and Transaction Monitoring
Does KYT replace KYC?
No. The KYT complements KYC, which establishes knowledge of the customer, the beneficial owner, and the risk level. The KYT monitors transactions carried out after the relationship has been established.
Can a small transaction trigger a TRACFIN alert?
Yes. There is no minimum amount that triggers suspicion. Regulatory thresholds are primarily used for customer identification, not to determine the existence of a risk. Even small amounts of cash can trigger an alert if they indicate splitting of payments, unusual behavior, or an attempt to circumvent the €1,000 limit on cash payments.
Does AP-Monitoring explain the alerts it generates?
Yes. AP-Monitoring is based on a Glass Box. Your teams can view the trigger criteria, the rules applied, and the elements required to qualify the alert.
Why request a demo of AP-Monitoring?
A demonstration allows us to analyze your risk scenarios, operational workflows, and integration needs in order to assess the effectiveness of your KYT system. We work with you to evaluate the suitability of a real-time KYT monitoring , taking into account your regulatory framework, workflows, and operational constraints.
