Examples of the types of monitoring systems firms should put in place include:

a) transaction monitoring systems that detect anomalies or suspicious patterns of behaviour, including the unexpected use of the product in a way for which it was not designed; the firm may be able to disable the product either manually or through on- chip controls until it has been able to satisfy itself that there are no grounds for suspicion;

b) systems that identify discrepancies between submitted and detected information, for example, between submitted country of origin information and the electronically detected IP address;

c) systems that compare data submitted with data held on other business relationships and that can identify patterns such as the same funding instrument or the same contact details;

d) systems that identify whether the product is used with merchants dealing in goods and services that are associated with a high risk of financial crime;

e) systems that link e-money products to devices or IP addresses for web-based transactions.