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AML/CFT Program (Red Flags (UNUSUAL REAL ESTATE ACTIVITY (Same notary…
AML/CFT Program
Red Flags
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Customer’s internet protocol (IP) address does not match the identifying information provided during online registration
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Corporate account has deposits or withdrawals primarily in cash, rather than checks.
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Customer makes frequent purchases of monetary instruments with cash in amounts less than the reporting threshold
Account in the name of a currency exchange house receives wire transfers and/or cash deposits under the reporting threshold.
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Corporate account shows little or no regular, periodic activity.
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ENHANCED DUE DILIGENCE
FATF acknowledges that there are circumstances where the risk of money laundering or terrorist financing is higher and enhanced CDD measures must be taken. include:
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• The ownership structure of the company appears unusual or excessively complex given the nature of the company’s business.
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The Basel Committee states that EDD may be for an individual planning to maintain a large account balance and conduct regular cross-border wire transfers or an individual who is a politically exposed person.
For higher risk customers, FATF recommends obtaining the approval of senior management to commence or continue the business relationship and requiring the first payment to be carried out through an account in the customer’s name with a bank subject to similar CDD standards.
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