Red Flags

1. Red Flags Part 2

2. Introduction • Purpose: • To show visually what bankers may see in transactional activity that may uncover certain financial crimes. • The red flags are reviewed from the FFIEC BSA / AML Manual as well as FATF reports on criminal activity

3. Introduction

4. Red Flags • Red Flag Examples Part 2 Money Laundering • The following examples are meant for bankers to visually note transactional activity they may notice in review of their everyday reports. These are only of few examples of many and will hopefully help to develop a reporting structure to make a more efficient and well documented AML Program. These examples are simple and brief, good launderers may have very complex and intricate laundering schemes • It’s important for bankers to stay up to date on all current information provided by law enforcement, FinCEN and your regulator.

5. Other Financial Crimes

6. Terrorist Financing

7. Terrorist Financing: • Terrorists generally finance their activities through both unlawful and legitimate sources. Unlawful activities, such as extortion, kidnapping, and narcotics trafficking, have been found to be a major source of funding. Other observed activities include smuggling, fraud, theft, robbery, identity theft, use of conflict diamonds and improper use of charitable or relief funds. In the last case, donors may have no knowledge that their donations have been diverted to support terrorist causes.

8. Terrorist Financing • Other legitimate sources have also been found to provide terrorist organizations with funding; these legitimate funding sources are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership, and personal employment.

9. What to look for Red Flags • Exact dollar amounts for all types of transactions • International transactions to “High Risk” locations • Look at source and destination of funds does the “flow” of the money make sense • Review beneficial ownership of the accounts • Business front (Non-profit or cash intensive business) • Cash ins in some cases are performed on the same business day, however, different branches are used.

10. What to look for Backroom Reports Review • Exact amount in the Wire, ACH, Cash and check reports • Transactions with exact dollar amounts (not all the time) • Look destination of funds where and who the funds go to and how they got there. • Are the funds going to places associated with your customer • Online payment transactions that have little information provided and are unusual for the type of business and / or account holder • Any linkage between customers that may be noted in CIP / CDD information (i.e. occupation type of business, expected activity etc) • Funds Transferred to high risk locations (i.e. off shore tax haven accounts)

11. Front Line staff: Key Points • Transactions with exact dollar amounts • Any comments the customer makes concerning the transactions or their business • Any mention of the reporting thresholds when deposits made. • The Bank is unable to obtain sufficient information or information is unavailable to positively identify originators or beneficiaries of accounts or other banking activity (using Internet, commercial database searches, or direct inquiries to a respondent bank).

12. Documentation needed • Notes from the front line on comments the customer may have made • Source and destination of funds • All web searches for information on the customer and customer’s business • If non-profit look for benefactors and type of non-profit • Obtain and document beneficial ownership of any business the customer may open or be associated with

13. Terrorist Financing • Customer owns non-profit and receives online donations from pay-pal as well as deposits funds from donations • From the donations customer then transfers funds to individuals that have no known association with the non-profit

14. Notice the exact amounts in and out Terrorist Financing From review of backroom reports look for large exact dollar deposits, withdraws and / or transfers in and out From CIP and CDD Reviews, review and document the type of non-profit and who are the benefactors from the funds Notice the wires out to high risk domestic locations

15. Summary

16. Terrorist Financing Possible Hawala • Customer owns cash intensive business and makes routine cash deposits into its business account. • The customer then shows wires out and international ACH transactions out to high risk areas to unknown beneficiaries

17. Terrorist Financing Possible Hawala Notice the business type, would it normally perform foreign wires Customer owns Sub Shop receives cash in that it deposits into its business account. The customer then shows wires out and Pay-Me ACH out to high risk areas and unknown beneficiaries Notice transfers may not be only wires some online payment systems allow transfers Notice exact amounts in and out

18. Summary

19. Terrorist Financing • Customer receives large and frequent deposits from online payments systems yet has no apparent online or auction business.

20. Suspicious Non-Cash Deposits / Terrorist Financing Customer receives large and frequent deposits from online payments systems yet has no apparent online or auction business.

21. Summary

22. Human Trafficking

23. Human Trafficking • Trafficking in Persons as the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs

24. What to look for Red Flags • Exact dollar amounts for all types of transactions • International transactions to “High Risk” locations • Look at source and destination of funds does the “flow” of the money make sense • Review beneficial ownership of the accounts • Business front (Non-profit or cash intensive business) • Cash ins in some cases are performed on the same business day, however, different branches are used. • Internet purchases, Point of sale, ATM and / or credit card transactions in high risk locations or on adult / unknown web sites

25. What to look for Backroom Reports Review • Exact amount in the Wire, ACH, Cash and check reports • Transactions with exact dollar amounts (not all the time) • Look destination of funds where and who the funds go to and how they got there. • Are the funds going to places associated with your customer • Online payment transactions that have little information provided and are unusual for the type of business and / or account holder • Any linkage between customers that may be noted in CIP / CDD information (i.e. occupation type of business, expected activity etc) • Funds Transferred to high risk locations (i.e. off shore tax haven accounts) • Internet purchases, Point of sale, ATM and / or credit card transactions in high risk locations or on adult / unknown web sites

26. Front Line staff: Key Points • Transactions with exact dollar amounts • Any comments the customer makes concerning the transactions or their business (i.e. reporting thresholds on any type of transactions) • The Bank is unable to obtain sufficient information or information is unavailable to positively identify originators or beneficiaries of accounts or other banking activity (using Internet, commercial database searches, or direct inquiries to a respondent bank).

27. Documentation Recommended • Notes from the front line on comments the customer may have made • Source and destination of funds • All web searches for information on the customer and customer’s business • If non-profit look for benefactors and type of non-profit • Obtain and document beneficial ownership of any business the customer may open or be associated with

28. Organized Crime and Drug Trafficking

29. Organized Crime and Drug Trafficking • Organized Crime A widespread group of professional criminals who rely on illegal activities as a way of life and whose activities are coordinated and controlled through some form of centralized syndicate. • Drug trafficking is a global illicit trade involving the cultivation, manufacture, distribution and sale of substances which are subject to drug prohibition laws.

30. What to look for Red Flags • Exact dollar amounts for all types of transactions • International transactions to “High Risk” locations • Look at source and destination of funds does the “flow” of the money make sense • Review beneficial ownership of the accounts • Business front (Non-profit or cash intensive business) • Cash ins in some cases are performed on the same business day, however, different branches are used. • Internet purchases, Point of sale, ATM and / or credit card transactions in high risk locations or on adult / unknown web sites

31. What to look for Backroom Reports Review • Exact amount in the Wire, ACH, Cash and check reports • Transactions with exact dollar amounts (not all the time) • Look destination of funds where and who the funds go to and how they got there. • Are the funds going to places associated with your customer • Online payment transactions that have little information provided and are unusual for the type of business and / or account holder • Any linkage between customers that may be noted in CIP / CDD information (i.e. occupation type of business, expected activity etc) • Funds Transferred to high risk locations (i.e. off shore tax haven accounts) • Internet purchases, Point of sale, ATM and / or credit card transactions in high risk locations or on adult / unknown web sites

32. Front Line staff: Key Points • Transactions with exact dollar amounts • Any comments the customer makes concerning the transactions or their business (i.e. reporting thresholds on any type of transactions) • The Bank is unable to obtain sufficient information or information is unavailable to positively identify originators or beneficiaries of accounts or other banking activity (using Internet, commercial database searches, or direct inquiries to a respondent bank).

33. Corruption / PEP

34. Politically exposed person • The term "politically exposed person" generally includes a current or former senior foreign political figure, their immediate family, and their close associates. Interagency guidance issued in January 2001 offers banks resources that can help them to determine whether an individual is a PEP

35. Identify the accountholder and beneficial owner, including the nominal and beneficial owners of companies, trusts, partnerships, private investment companies, or other legal entities that are accountholders. • Seek information directly from the account holder and beneficial owner regarding possible PEP status. • Identify the accountholder’s and beneficial owner’s country of residence and the level of risk for corruption and money laundering associated with these jurisdictions. • Obtain information regarding employment, including industry and sector and the level of risk for corruption associated with the industries and sectors.

36. Check references, as appropriate, to determine whether the account holder and beneficial owner is or has been a PEP. • Identify the account holder’s and beneficial owner’s source of wealth and funds. • Obtain information on immediate family members or close associates either having transaction authority over the account or benefiting from transactions conducted through the account. • Determine the purpose of the account and the expected volume and nature of account activity. • Make reasonable efforts to review public sources of information. These sources will vary depending upon each situation; however, banks should check the accountholder and any beneficial owners of legal entities against reasonably accessible public sources of information (e.g., government databases, major news publications, commercial databases and other databases available on the Internet, as appropriate).

37. What to look for Red Flags • Exact dollar amounts for all types of transactions • International transactions to “High Risk” locations • Look at source and destination of funds does the “flow” of the money make sense • Review beneficial ownership of the accounts • Business front (Non-profit or cash intensive business) • Cash ins in some cases are performed on the same business day, however, different branches are used. • Internet purchases, Point of sale, ATM and / or credit card transactions in high risk locations or on adult / unknown web sites

38. What to look for Backroom Reports Review • Exact amount in the Wire, ACH, Cash and check reports • Transactions with exact dollar amounts (not all the time) • Look destination of funds where and who the funds go to and how they got there. • Are the funds going to places associated with your customer • Online payment transactions that have little information provided and are unusual for the type of business and / or account holder • Any linkage between customers that may be noted in CIP / CDD information (i.e. occupation type of business, expected activity etc) • Funds Transferred to high risk locations (i.e. off shore tax haven accounts) • Internet purchases, Point of sale, ATM and / or credit card transactions in high risk locations or on adult / unknown web sites

39. Front Line staff: Key Points • Transactions with exact dollar amounts • Any comments the customer makes concerning the transactions or their business (i.e. reporting thresholds on any type of transactions) • The Bank is unable to obtain sufficient information or information is unavailable to positively identify originators or beneficiaries of accounts or other banking activity (using Internet, commercial database searches, or direct inquiries to a respondent bank).

40. Ponzi Schemes

41. A Ponzi scheme is an investment fraud that involves the payment of purported returns to existing investors from funds contributed by new investors. Ponzi scheme organizers often solicit new investors by promising to invest funds in opportunities claimed to generate high returns with little or no risk. In many Ponzi schemes, the fraudsters focus on attracting new money to make promised payments to earlier-stage investors and to use for personal expenses, instead of engaging in any legitimate investment activity

42. What to look for Red Flags • Exact dollar amounts for all types of transactions • International transactions to “High Risk” locations • Look at source and destination of funds does the “flow” of the money make sense • Review beneficial ownership of the accounts • Business front (Non-profit or cash intensive business) • Cash ins in some cases are performed on the same business day, however, different branches are used. • Internet purchases, Point of sale, ATM and / or credit card transactions in high risk locations or on adult / unknown web sites

43. What to look for Backroom Reports Review • Exact amount in the Wire, ACH, Cash and check reports • Transactions with exact dollar amounts (not all the time) • Look destination of funds where and who the funds go to and how they got there. • Are the funds going to places associated with your customer • Online payment transactions that have little information provided and are unusual for the type of business and / or account holder • Any linkage between customers that may be noted in CIP / CDD information (i.e. occupation type of business, expected activity etc) • Funds Transferred to high risk locations (i.e. off shore tax haven accounts) • Internet purchases, Point of sale, ATM and / or credit card transactions in high risk locations or on adult / unknown web sites

44. Front Line staff: Key Points • Transactions with exact dollar amounts • Any comments the customer makes concerning the transactions or their business (i.e. reporting thresholds on any type of transactions) • The Bank is unable to obtain sufficient information or information is unavailable to positively identify originators or beneficiaries of accounts or other banking activity (using Internet, commercial database searches, or direct inquiries to a respondent bank).