Appendix1-AmendmentstoGuidanceNotesof5June2020e-KYCUpdates_1671216593_1679951967.pdf

Here are the key points summarized:

Suspicious Transactions

• Large cash transactions
• Unusual or complex financial structures
• Movement of funds to and from countries with poor anti-money laundering (AML) regulations
• Use of shell companies, trusts, or other legal entities
• Cash-intensive businesses without adequate records
• Multiple accounts in the same name
• Excessive or unusual withdrawals
• Unexplained wealth or income

Indicators of Money Laundering

• Cash deposits that exceed normal business activity
• Large transactions involving bearer shares or other unregistered securities
• Use of intermediaries or third-party payments
• Complex financial structures without a clear purpose
• Unusual payment patterns, such as large sums paid in cash
• Excessive use of credit cards or other debt instruments

Guidance for Financial Services Providers (FSPs)

• FSPs should be alert to unusual transactions and investment behavior
• Particular care is needed when dealing with complex financial structures or transactions involving third parties
• FSPs should report suspicious activity to their MLRO or DMLRO
• The reporting officer should provide a brief explanation for regarding the transaction as suspicious

Reporting Form

• The FSP internal (suspicious activity) report form should include information such as:
  • Customer name and account details
  • Date of opening and customer's birthdate
  • Nationality, passport number, and identification references
  • Address and contact information for the customer
  • Details of transactions arousing suspicion
  • Any other relevant information

Remember that this is not an exhaustive list, and FSPs should remain vigilant and report any suspicious activity to their MLRO or DMLRO.