SUSPICIOUS TRANSACTIONS INDICATORS LIST

Published date: 19.03.2007 17:44 | Author: Indikatori sumnjivih transakcija

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SUSPICIOUS TRANSACTIONS INDICATORS LIST
(supplement) -March 2007


1. Announced block trade in shares at price slower than the market ones, when buyers are unknown or newly formed companies, and particularly the companies registered on offshore territories.

2. Client invests in prime and very promising shares, without expressing an interest in the results, or suddenly and without purpose sells the shares.

3. Client often changes brokerage houses in an effort to conceal the scope of his/her business and the financial standing.

4. Trades and transactions carried on through a brokerage-dealer house that has previously been punished by the Securities Commission for irregular or undue carrying on business.

5. Trade in securities with a planned loss, when a client frequently purchases securities and soon after sells them below cost.

6. Trade in shares that have been the subject of collateral on the basis of granted loans to the share owners.

7. Client has poor reputation; he/she is known for illegal activities from the past or connections with persons related to illegal activities.


SUSPICIOUS TRANSACTION INDICATORS IN BANK OPERATION


UNUSUAL CHANGES ON ACCOUNTS

1. Depositing a higher amount of cash as deposit for the purpose of obtaining credit, and afterwards an unexpected request form a client to pay of the credit before the deadline.

2. Client deposits considerable amounts on an account and gives an order to a bank for the amounts to be transferred on the accounts of a great number of persons, especially in cases when there is no rational explanation or economic justification for such transactions.

3. Frequent transfers to huge and rounded amounts.

4. Frequent transactions on the basis of advance payments or advance returns that are substantiated by a client with the non- execution of commercial contracts.

5. Transfers of huge amounts in foreign countries from the account of a client when the account balance originates from numerous cash deposits on different accounts of clients at one or more banks.

6. Small enterprise operating on only one location performs transactions of depositing or withdrawing funds in more branches of the same bank, which could be evaluated as impractical for that enterprise.

7. Considerable increase of the amount, or frequency of cash deposits or withdrawals from the account of an enterprise whose activity is providing professional and consulting services, especially when the deposited funds are immediately transferred on other accounts.

8. Transactions between private and business account of an enterprise, which do not indicate to a clear economic justification.

9. Transactions including withdrawal of funds soon after the funds have been deposited at an obligor (only goes through an account), when this rapid withdrawal of funds is not justified in the business activity of a client.

10. Unexpected/ sudden paying off a debt without a convincing explanation.

11. Loans granted by off-shore companies.

12. Unexplained electronic transfers of funds by a client.

13. Accounts are used for receiving or paying of huge amounts, but they do not show so called normal activities related to the operating, such as, for example, payment of salaries, paying bills etc.

14. Transactions with a country that is considered as non-cooperative by Financial Action Task Force (FATF) or business relationships with customers whose permanent residence is in such countries.

15. Issuing payable guarantees by a third party unknown to the financial institution, which do not have a clear relationship with a client or a good reason for offering such guarantees.

16. Transfers of huge amounts of money with instructions to pay of the funds to the beneficiary in cash.

17. A great number of different individuals paying in deposits on the same number of accounts.


BEHAVIOUR OF CLIENTS AND EMPLOYEES


1. Client has never been employed, and owns considerable funds on the accounts.

2. Client holds open accounts in few branches of the same bank, deposits cash on each of them, and the sum of payments is a considerable one.

3. Client often deposits funds for which he/she states that they originate from asset sale, while the existence of the asset is questioned.

4. Authorised persons for disposing of the funds on the account of an enterprise refuse to provide complete data on business of the enterprise.

5. Client makes cash deposits on the account of his/her enterprise with the purpose of paying for founders loan or increase of founders deposit.

6. Client withdraws high sums of money from the account on which significant funds have been transferred on the basis of a credit granted from a country that does not implement the regulations from the prevention of money laundering area.

7. Client transfers funds on the account in a country his/her enterprise has not had business relationship or receives remittances from business entities he/she had no connections and previous transfers.

8. Orderer or the user/beneficiary of the remittance is the citizen of the country that does not apply regulations from the prevention of money laundering area, or which is on the consolidated list of the Sanctions Committee on the basis of UN Security Council Resolution 1267.

9. Client carries out transactions with persons or companies registered in the countries known as narco-countries and through whose territory narcotics are distributed, or where very rigid laws on bank and business data secrecy are in force.

10. Client a legal person, submits a loan application, despite the fact that the economic and financial standing indicators do not imply the clients need for a loan. The funds from the loan are afterwards transferred on the accounts in an off-shore bank, or in the favor of a third party, or are used without purpose.


11. When carrying out a transaction, a client is supervised by a third person.

(Client carries out a transaction accompanied by a person that obviously supervises the behaviour of the client or insists on the transaction to be carried out fast).

12. Client frequently deposits or withdraws funds in the amounts that are somewhat lower than the threshold required for identifying and reporting.

13. Client requires the business relationship to be terminated and to establish a new relationship with a bank in his own name, or in the name of a family member, with no documented traces left.

14. Client frequently (in a short period of time) via cash dispensers withdraws cash in the amounts that are under the threshold required for identifying and reporting.



WITH REGARD TO CARRYING OUT THE ELECTRONIC FUNDS TRANSFER

1. Client transfers large amounts of money abroad with cash payment order to the foreign entity.

2. Client receives large amounts of money, from foreign locations, that contains cash payment orders.

3. The amount of electronically transferred assets is out of usual business transactions of that client.

4. Client carries out fund transfer towards counties known for drugs production and export .

5. Client carries out transactions within countries known for high level of bank and business secrecy, except when there is about countries that have accepted international standards on prevention of money laundering.

6. Client carries out electronic fund transfer in/from free or off shore zone, even if this activity is not usual for clients business activities.

7. Client carries out fund transfers (in/from country) and as a purpose for transaction states different derivative financial instruments (options, futures)



GENERAL INDICATORS OF SUSPICIOUS TRANSACTIONS

Legal and natural persons, business organizations, and entrepreneurs engaged in a trade or business as listed in Article 3, Items 2, 3, 6, 7, 8, 9 and 10 of the Law on the Prevention of Money Laundering


1. Client carries out real estate businesses (purchase and sale) in cash for himself, members of family and third parties, exceeding total amoun150.000.

2. Client inquires on unusual ways of payment.
3. Client does not want to be identified in case of real estate purchase in cash or identifies with forged data and documents.

4. Client that is famous from public life purchase real estates in larger amounts and its values diverge from clients property status.

5. Client which purchases a real estate is a young person, but it is obvious that client possess luxury status symbols (precious cars, motorbikes, vessels, watches etc.)

6. Client/ resident and non resident purchase a real estate for domestic legal person, even if it is obvious that purpose is trade for natural person/ non resident.

7. Client natural or legal person inquires or carries out real estate transactions for natural and legal persons, residents and non residents, that comes from the off shore destinations, or for off shore companies, and also from countries known for drug production and distribution, states that dont have arranged identification systems and systems for prevention of money laundering and countries from so called black list, countries that are suspected to encourage terrorist activities and terrorism financing.
8. Paying large amounts of insurance premium.

9. Request of insurance beneficiary for insurance payment or return of insurance premium in cash and in case of a large amount.

10. Large insurance amounts with more insurance polices, that are concluded in short time period, are paid in cash.

11. There is reasonable suspicion that insurance policies are concluded under false names, under other peoples names or registered false addresses.

12. One person is an owner of a large number of insurance policies, and especially if the insurance contracts are concluded in short time period.

13. Owner of insurance policy make changes in insurance contract and demands insurance policy with larger premium or demands to change monthly payment for annual payment or demands lump sum payment, and it does not correspond with its financial standing.

14. Cancelling insurance policy soon after concluding insurance policy contract soon after concluding insurance policy contract, especially when there is large amount premium.

15. Client demands compensation from insurance, money that is demanded on the basis of compensation in case of cancellation of policy or overpaid amount of insurance premium to be paid off to a third party or transferred to the account of natural or legal person on the territory of the state where are applied high standards in the area of money laundering and in which are prescribed strict regulations on confidentiality and secrecy of bank and business data.

16. Client accepts unfavourable terms of insurance contract, with regard to his health condition and age.

17. Companies that are owners of insurance policies pay on behalf of their employees unusually large insurance premiums or cancel policies in very short time period from the date of concluding insurance contract.

18. Companies purchase insurance policies for their employees, and number of employees is lower than number of purchased policies: polices are issued even for persons that are not employed in company.

19. Insurance contract is concluded by person who carried out illegal activities in past or insurance contract is concluded by person that in some manner can be connected with these activities.

20. Contractor insurance or the insured insists on transaction secrecy, i.e. not to report the amount of the insurance premium or the amount of the insurance to the APML despite the fact that it is a statutory obligation of the insurer. A customer attempts, by plead or bribe, to convince the employees in the insurance company to represent his/her interests which is against the law.