Suspicious Transactions

James Wright

Cash Transactions

1. Cash deposits or withdraws for considerable, unusual amounts of money, made by natural persons or other entites when their customary operations is done through checks or other monetary instruments, and their declared business nature does not justify transactions of said type and volume.

Substantial increase of cash deposits from natural persons or entities without having clear reason to occur, specially when deposits are transferred in the short term to destinations usually not related to customer.

Cash

Cash deposits made by customers through successive low amount transactions but the total of them turns into a significant amount.

Exchange of huge number of low currency bills into higher currency bills

Deposit or other transactions which involve forgery or false documents

Cash deposits of huge amounts of money at non-office hours avoiding thus direct contact with the entity staff.

Cash

Frequent or substantial money exchange through the cash desk (foreign currency in local currency) when the customer’s business or professional nature keeps no relation to it.

Frequent cash deposits, or withdrawals without any commercial purpose related to customary nature and volume of business.

Customer does not request cash when nature of his business calls for intensive use of ready cash

Bank Account Transactions

Transactions carreid out by customer whose declared profile is inconsistent with the operation, giving ground to the suspicion of acting on other’s behalf.

Different accounts on behalf of the same customer when their total deposit amount is highly significant and keeps no relation to his declared business activity.

Accounts on behalf of natural or artificial persons, used to deposit huge amounts of money not clearly related to the account holder’s business or activity

Account transactions

Opening of accounts where customers refuse to disclose standard information required, where information presented is not sufficient, forged or difficult to be verified by the financial entity.

Settlement of payments by means of deposits credited on the same day or the day before.

Substantial deposits or withdrawals related to accounts which have been dormant for long periods.

Account transactions

Accounts receiving huge sums of money from abroad, these sums being inconsistent with customary activity.

Customers jointly and simultaneously using individual cash-tellers to make substantial financial transactions or operations in foreign currency.

Company representatives avoiding contact with the bank.

Customer who fails to produce the information which would allow them under standard circumstances to be granted credits or any other banking service

Account Transactions

Too many natural persons carrying out different transactions on the same account, with no appropriate reason whatsoever.

Accounts frequently receiving funds from the so-called “offshore Countries” including tax haven courtiers and FATF designated non-cooperating countries.

Accounts frequently wiring funds to countries designated above.

Account Transactions

Customer accounts with substantial transactions through international transfer systems or electronic means of payment (EMP) inconsistent with nature and volume of the customer’s business.

Dormant accounts or largely inactive ones but used from time to time to receive or send large amounts of money inconsistent with nature and volume of the customer’s business or without any relation whatsoever.

Account Transactions

Accounts opened by an artificial person or an entity under same domicile as other companies and entities’ and where aforementioned persons are authorized signatories when apparently there is no reason whether legal or economic to hold such an agreement. (Example: person holding the position of Director in various corporations of the same location). Special attention should be paid to companies or entities located in offshore countries.

Account Transactions

Account opened on behalf of an entity, a foundation, an association or a mutual fund, whose transaction amounts exceed the level of standard or regular incomes without a sound economic or legal ground consistent with the activity declared and customer‘s profile.

Foreign Trade Transactions

Change of name and address of beneficiary to Bill of Credit just before payment accrual.

Change of payment place of the Bill of Credit Transactions by means of Bill of Credit and

other negotiable instruments to move funds among countries where said trade is unusual compared to the customer’s regular activity.

Foreign trade transactions- imports and exports- highly sophisticated carried out by means of various mechanisms where there is no actual movement of merchandise.

Foreign Trade Transactions

Forged exports or overbilling/underbilling of export transactions.

Forged imports or overbilling/underbilling of import transactions.

Foreign trade transactions priced inconsistently with market prices, or when their volume greatly differ from usual volumes traded by customer and/or sector.

Foreign Trade Transactions

Wire transfers which lack data needed to reconstruct the transaction.

Foreign trade transactions- especially transfers- where originator or beneficiary is a foundation, association or any other non-profit entity unable to convincingly evidence the origin of funds involved. Additionally, same origin must perfectly fit the profile of customer declared by said entity.

Investment-related Transactions

for trading commercial paper secured at the financing entity, inconsistent with the customers business

Customer’s request for services related to investment portfolio (whether foreign currency, stocks/shares or trusts), where the fund source is unclear or not consistent with the customers profile.

Investment

Significant and unusual transactions through trust fund accounts.

Frequent use of special investment accounts by irregular customers when holder of account is the very financial entity. Transactions related to mutual funds.

Regular transactions with negotiable instruments- securities and bonds – by means of trading them on the day, in identical volume and nominal values, while taking advantage of quotation differences. These are not consistent with customer’s profile.

International Activity –related Transactions

Transfers of large amounts of money to-and-fro abroad, where instructions are to pay cash

Customers referred by a branch, subsidiary or foreign bank located in countries or territories deemed as “Tax Havens’ or non-cooperative by FATF.

Customers making or receiving regular payments involving large amounts of money, including wire transactions, to and from countries deemed as “Tax Havens” or non cooperative by FATF.

International Activity- related Transactions

Accrual of large balances inconsistent with the sales or billing operation of customer and subsequent transfers to accounts abroad.

Wire transfers of funds carried out by customer, under circumstances of immediate credit and debit or even without passing through his account.

Frequent transactions using traveler's checks, foreign money orders or any other negotiable instrument, inconsistent with the customer’s declared activity and profile.

International

Wire transfer of large amounts of money without data allowing the clear identification of said transactions.

Use of many personal accounts or non-profit entities or charity entities’ to collect funds and then transfer them immediately or after a short period to beneficiaries abroad.

International

Transactions of any type whatsoever where customers object to produce standard required information, give insufficient information whether false or difficult to be verified by the financial/exchange entity.

Guaranteed or Non-guaranteed Loans

Customers who cancel their loans unexpectedly Loans guaranteed by securities deposited in the

financial entity or by third parties, origin of which is unknown or amounts are not consistent with the status of the borrower.

Customer’s application to be granted financing by the financial entity when the customer is unable to evidence his capacity to pay in virtue of inconsistency with declared activity or because of lack of elements required to determine origin of funds to be used to settle the amount due. Special attention must be paid to real estate loans or other assets subject to register.

Loans

Loans secured by third parties who apparently have no relationship to customer.

Mortgage or loans secured by real estate, when cancellations is to be formalized in a different jurisdiction.

Loans

Sale of properties seized by creditor where there is no legal ground to prove origin of funds used by buyer of said properties of his capacity to pay.

Customers asking for loans on working capital and upon its crediting they immediately transfer funds to accounts abroad, without having legal ground for that.

Customers asking for loans which may be linked to term deposits.