Revised Central Bank-AMLA Guidelines - Anti-Money Laundering ...

AML/CFT GUIDELINEISSUED BY THECENTRAL BANK OF BARBADOSIN CONJUNCTION WITH THE ANTI-MONEY LAUNDERING AUTHORITYMAY 2011Cash TransactionsClient starts conducting frequent cash transactions in large amounts when this hasnot been a normal activity in the past.Frequent exchanges small bills for large ones.Deposits of small amounts of cash on different successive occasions, in such away that on each occasion the amount is not significant, but combines to total avery large amount. (i.e. “smurfing”).Consistently making cash transactions that are just under the reporting thresholdamount in an apparent attempt to avoid the reporting threshold.Stated occupation is not in keeping with the level or type of activity (e.g. a studentor an unemployed individual makes daily maximum cash withdrawals at multiplelocations over a wide geographic area).Unusually large deposits or withdrawals of cash by an individual or a legal entitywhose apparent business activities are normally carried out using cheques andother monetary instruments.Multiple and frequent purchase or sale of foreign currency by a tourist.Multiple and frequent large withdrawals from an ATM using a local debit cardissued by another financial institution.Multiple and frequent large withdrawals from an ATM using debit or credit cardissued by a foreign financial institution.Deposit ActivityAccount with a large number of small cash deposits and a small number of largecash withdrawals.Funds are being deposited into several accounts, consolidated into one andtransferred outside the country.Multiple transactions are carried out on the same day at the same branch but withan apparent attempt to use different tellers.Anti-Money Laundering/Combating Terrorist Financing Guideline May 2011 45Bank Supervision DepartmentCENTRAL BANK OF BARBADOS