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

AML/CFT GUIDELINEISSUED BY THECENTRAL BANK OF BARBADOSIN CONJUNCTION WITH THE ANTI-MONEY LAUNDERING AUTHORITYMAY 2011Fiduciary BusinessClient seeks to invest a large sum of money with no apparent interest in the details of theproduct (e.g. mutual fund) and does not enquire about the characteristics of the productand /or feigns market ignorance.Corporate client opens account with large sum of money that is not in keeping with theoperations of the company, which may itself have recently been formed.Formation of a legal person or increases to its capital in the form of non-monetarycontributions of real estate, the value of which does not take into account the increase inmarket value of the properties used.EmployeesLifestyle, financial status or investment activity is not in keeping with employee’s knownincome.Reluctance to go on vacation, to change job position or to accept a promotion, with noclear and reasonable explanation.Employee frequently receives gifts &/or invitations from certain clients, with no clear orreasonable justification.Employee hinders colleagues from dealing with specific client(s), with no apparentjustification.Employee documents or partially supports the information or transactions of a particularclient, with no clear and reasonable justification.Employee frequently negotiates exceptions for a particular client(s).Anti-Money Laundering/Combating Terrorist Financing Guideline May 2011 49Bank Supervision DepartmentCENTRAL BANK OF BARBADOS