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Guideline on Anti-Money Laundering and the Combating of Terrorist Financing(c)(d)Large or unusual settlements of securities transactions in cash.Buying and selling of a security with no discernible purpose or in circumstances which appearunusual.4. Money Laundering by International Activity(a)(b)(c)(d)(e)(f)Customers introduced by an overseas branch, affiliate or other bank based in countries whereproduction of drugs or drug trafficking may be prevalent.Use of Letters of Credit and other methods of trade finance to move money between countrieswhere such trade is not consistent with the customer’s usual business.Customers who make regular and large payments that cannot be clearly identified as bona fidetransactions to, or who receive regular and large payments from, countries which are commonlyassociated with the production, processing or marketing of drugs; or who conduct transactions withproscribed terrorist organizations.Accumulation of large balances, not consistent with the known turnover of the customer’s business,and subsequent transfer to account(s) held overseas.Unexplained electronic fund transfers by customers on an in and out basis or without passingthrough an account.Frequent paying in of travellers’ cheques, foreign currency drafts or other negotiable instruments.5. Money Laundering Involving Employees and AgentsFinancial Institutions should pay particular attention to the following: -(a)(b)(c)Changes in employee characteristics, e.g., sudden lavish lifestyle or avoidance of vacations.Any dealing with an agent where the identity of the ultimate beneficiary or counterparty isundisclosed, contrary to normal procedure for the type of business concerned.Refusal of a change in responsibility such as a promotion.6. Money Laundering by Secured and Unsecured Lending(a)(b)Customers who repay problem loans unexpectedly.Requests to borrow against assets held by the financial institution or a third party, where the originof the assets is not known or the assets are inconsistent with the customer’s apparent financialposition.Page 51 of 75
Guideline on Anti-Money Laundering and the Combating of Terrorist FinancingRequest by a customer to provide or arrange finance where the source of the customer’s financialcontribution to a deal is unclear, particularly where property is involved.7. Provision of Safe Custody and Safety Deposit BoxesWhere facilities to hold boxes, parcels and sealed envelopes in safe custody are made available, it isexpected that Institutions will follow the identification procedures set out in these Guidelines.Page 52 of 75
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