marketing purposes, let the client know that as well because often clients are more concerned about privacy and security issues, and reassuring them may be helpful. STRs must be submitted to the FIU within 5 days of the date that the Compliance Officer deems the activity to be suspicious. In order to provide enough time for the Compliance Officer to properly investigate the incident, make an official determination and possibly file a report with the FIU, the UTF must be submitted on the same day that the activity occurs. Suspicious Indicators and Red Flags There are a wide variety of factors that can indicate that a client’s activity may be related to money laundering or terrorist financing. These include behaviours, as well as transaction patterns. When it comes to concerns related to suspicious activity, trust instincts if something does not feel right (whether or not any “your” – of these indicators are present), file a UTF with the Compliance Officer. The indicators provided below, are a sample contained on the FIU website, the FIU’s STR Guidelines 2014, and generally accepted red flags, which will be augmented regularly by the Compliance Officer, based on trends observed in banking, trade financing, and/or the financial services industry. Suspicious Indicators and Red Flags Related to Money Laundering Unwillingness or Inability to Provide Required Information Information provided by a client is insufficient or their behaviour seems unusual; A client provides unusual or altered identification documents that cannot be readily verified; A client uses a different Taxpayer Identification Number with variations of their name; A business client is reluctant, or unable, to provide complete information about the nature and purpose of anticipated funds transfer activity, its key personnel or its physical location; A client’s home or business telephone is disconnected; The client’s transaction activity differs from that which would be expected on the basis of their business/occupation; Efforts to Avoid Reporting or Recordkeeping Requirements A client tries to persuade an employee not to file the required regulatory or internal reports, in order to avoid the maintenance of required records; A client is reluctant to provide information needed to file a mandatory report, to have the report filed, or to proceed with a transaction after being informed that the report must be filed; A client asks to be exempted from regulatory reporting, identification or recordkeeping requirements; or
marketing purposes, let the client know that as well because often clients are more concerned about privacy and security issues, and reassuring them may be helpful. STRs must be submitted to the FIU within 5 days of the date that the Compliance Officer deems the activity to be suspicious. In order to provide enough time for the Compliance Officer to properly investigate the incident, make an official determination and possibly file a report with the FIU, the UTF must be submitted on the same day that the activity occurs. Suspicious Indicators and Red Flags There are a wide variety of factors that can indicate that a client’s activity may be related to money laundering or terrorist financing. These include behaviours, as well as transaction patterns. When it comes to concerns related to suspicious activity, trust “your” instincts – if something does not feel right (whether or not any of these indicators are present), file a UTF with the Compliance Officer. The indicators provided below, are a sample contained on the FIU website, the FIU’s STR Guidelines 2014, and generally accepted red flags, which will be augmented regularly by the Compliance Officer, based on trends observed in banking, trade financing, and/or the financial services industry. Suspicious Indicators and Red Flags Related to Money Laundering Unwillingness or Inability to Provide Required Information Information provided by a client is insufficient or their behaviour seems unusual; A client provides unusual or altered identification documents that cannot be readily verified; A client uses a different Taxpayer Identification Number with variations of their name; A business client is reluctant, or unable, to provide complete information about the nature and purpose of anticipated funds transfer activity, its key personnel or its physical location; A client’s home or business telephone is disconnected; The client’s transaction activity differs from that which would be expected on the basis of their business/occupation; Efforts to Avoid Reporting or Recordkeeping Requirements A client tries to persuade an employee not to file the required regulatory or internal reports, in order to avoid the maintenance of required records; A client is reluctant to provide information needed to file a mandatory report, to have the report filed, or to proceed with a transaction after being informed that the report must be filed; A client asks to be exempted from regulatory reporting, identification or recordkeeping requirements; or
Standard-Commerce-Bank-AML-Procedures-for-All-Staff-2016.docx