guideline on anti-money laundering and the combating of terrorist ...

Guideline on Anti-Money Laundering and the Combating of Terrorist FinancingMTB, the amount of information collected may be broadened to include details of the recipient of the funds. Thisinformation will assist MTBs to determine whether there is any risk that the customer is utilising multiple recipients tofacilitate money laundering or whether multiple customers are remitting multiple small sums that are accumulatedwith one recipient.Indicators of the Misuse of MTBsThe following activity may be suspicious and indicate money laundering or other illegal activity through the misuse ofMTBs.Transactions Which Do Not Make Economic Sensea) Transactions which are incompatible with the licensee’s knowledge and experience of the customer in questionor with the purpose of the relevant business transaction.b) A customer or group of customers attempting to hide the size of a large cash transaction by breaking it intomultiple, smaller transactions by, for example, conducting the smaller transactions -i. at different times on the same day;ii. with different MTB cashiers on the same day or different days; andiii. at different branches/offices of the same MTB.c) Transactions that cannot be reconciled with the usual activities of the customer.d) A business customer sends or receives money transfers to/from persons in other countries without an apparentbusiness reason or gives a reason inconsistent with the customer’s business.e) A business customer sends or receives money transfers to or from persons in other countries when the natureof the business would not normally involve international transfers.Transactions Involving Large Amounts of Casha) Frequent transactions of large cash amounts that do not appear to be justified by the customer’s businessactivity.b) Large and regular payments that cannot be identified as bona fide transactions, to countries associated with theproduction, processing or marketing of narcotics or other illegal drugs.c) Cash payments remitted to a single account by a large number of different persons without an adequateexplanation.Page 59 of 75