INDICATORS OF SUSPICIOUS TRANSACTIONS

1. Upon opening of account
2. Upon performing of transactions
3. Upon analysis of transactions


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1. Upon opening of account
    a. Suspicion of straw man
    • - The person is using outside assistance for filling of documents or can not fill them in
      - The person does not know actual owners of the trading company, location of the trading company or contact data
      - The person does not know character of the business of the company and possible partners
      - The person can not explain the need for ordered services (amount of settlement limits)
      - The person is listed in the list of known straw men
    b. Suspicion of front
    • - Owners and/or representatives of the trading company can not be unambiguously identified in the documents
      - The trading company has been registered in the territory belonging into the "black list" of FATF
      - The trading company has been registered in offshore region
      - Founders of the trading company can be classified as "suspicious"
      - Paid starting capital is promptly taken out or sent back
    c. Unusual documents
    • - Authorisations or identification documents of representative are not correct or valid
      - Submitted documents cause suspicion of forgery or have evident signs of forgery
      - Documents of non-residents are not valid (requirements of legalisation etc. have been ignored)
    d. Other suspicions
    • - Appearance of the person does not comply with his/her activities or statement of will
      - 2 or more cash cards are ordered with extraordinarily high limits
      - account is opened in bank office, which location has no direct relation to the trading company or person
2. Upon performing of transactions
    e. Unusual cash transaction
    • - Single large payments or withdrawals of cash
      - Payment of single large sums onto the account of private person, which are promptly withdrawn in cash or with cash card
      - Regular cash payments onto the account of private person also in smaller sums, which are transferred in larger sums to single accounts
      - Regular currency exchange in large sums
      - Regular exchange of smaller notes against notes with higher value
      - Purchase of financial services (securities, insurance products, shares of funds etc.) in large amounts for cash
      - Payment of taxes in large amounts in cash
      - Cash transfers to another country without opening of account
    f. Unusual transaction on account
    • - Single extraordinarily large transfer for the benefit of a client not having occurred earlier or a client registered in offshore region
      - Payments of different persons onto one account without sufficient explanation
      - On side of the transfer is credit or financial institution registered in offshore region
      - Large transfers with credit or financial institutions located in the territories belonging into the "black list" of FATF
      - Unjustified large return of VAT from the Tax Board
      - Frequent large wins from casinos or income from the sale of real estate or vehicles
      - Regular payment for luxury goods (cars, art treasures, real estate etc.)
      - Purchase of financial services (securities, insurance products, shares of funds etc.) in large amounts
      - Large purchases and sales of e-money
      - Regular payments for the use of internet-based financial instruments (e.g. SunBill, Privacy Tools etc.)
3. Upon analysis of transactions
    g. On the basis of random choice
    • - Paid (large) sums are withdrawn quickly in cash
      - Paid sums are withdrawn in ATM of other banks (countries)
      - Paid sums are withdrawn through other bank offices
      - Large deposit transactions made through ATM
      - Systematic payment of cash by persons, who are not dealing with retail or service
      - Several cash payments onto one account from different bank offices on one day, which give large total sum
    h. In relation with other transactions
    • - Circulation of large sums in closed circle (between different credit institutions)
      - Flows of large sums (between different persons) within one credit institution in one day
    i. On the basis of previous information (not from the bank)
    • - The person is using his/her account (multi-account) for mutual settlements of his/her other clients
      - Persons, who had no real commercial activities (during the previous year, after opening of account)
      - The person is connected with criminal transactions or persons