The requirement to report suspicious transactions states that banks, financial institutions, cash dealers or members of relevant professions shall make a report to the FIA on any transaction which they have reason to believe may be a suspicious transaction.

Ways of Reporting Where there is a business relationship, a suspicious transaction will often be one which is inconsistent with customer’s known, legitimate or personal activities or with the normal business for that type of account. Therefore, the first key to recognition is knowing enough about your customer and customers business to recognize that a transaction or series of transactions, are unusual. Reliance on what should be reported is therefore mainly on ones assessment based on knowledge and experience as well as specific circumstances of the transaction. The assessment should therefore be based on a reasonable evaluation of relevant factors including the knowledge of the clients business, financial history, background and behavior. Section 35 and 36 of the MLA therefore only provides indicators of suspicious transactions that might be useful in helping you assess whether a transaction is suspicious and should be reported, some of which include; .

Identity of client

- False identification documents

- Identification documents which could not be verified within reasonable time

- Accounts opened with names very close to other established business entities

Background of Client
- Suspicious background or links with known criminals
Multiple Accounts
- Large number of accounts having a common account holder, introducer or authorized signatory with no rationale

- Unexplained transfers between multiple accounts with no rationale

Activity in accounts
- Unusual activity compared with past transactions

- Sudden activity in dormant accounts

- Activity inconsistent with what would be expected from declared business

Nature of transactions
- Unusual or unjustified complexity

- No economic rationale or bonafide purpose

- Frequent purchases of drafts or other negotiable instruments with cash

- Nature of transactions inconsistent with what would be expected from declared business

Value of transactions
- Value just under the reporting threshold amount in an apparent attempt to avoid reporting

- Value inconsistent with the client’s apparent financial standing

News & Updates

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