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The FIAU has recently published 3 documents meant to provide subject persons with insights on suspicious activity and STRs in various sectors.  The documents include typologies and actual case studies which can be of interest for subject persons predominantly in the course of carrying out and/or updating the Business Risk Assessment and Customers Risk Assessment.

Fact Sheet: Cash usage, tax crimes, corruption and bribery

Cash Transactions

ATM Deposits: The predominant alleged predicate offence in this instance are tax crimes, followed by human trafficking and illicit traffic in narcotics.

ATM Withdrawals:  the alleged predicate offence in this service are terrorism activities, fraud and tax crimes

OTC cash deposits and withdrawals:  the predicate offence in OTC cash services are predominantly focused on illicit traffic in narcotics, participation in organised criminal groups, terrorism financing activities, corruption and bribery.

Tax Crimes

Tax-related offences were mostly flagged in STRs submitted by investment licensees, credit institutions, insurance licensees, PSPs as well as accountants and auditors.

Corruption and Bribery

85% of STRs submitted by SPs in related to suspicion of bribery and corruption were filed by credit institutions (52%), remote gaming companies (13%), investment services licensees (11%) and company service providers (9%).

Most commonly reported red flags included entities or individuals adversely known to open source information; and transactional activity inconsistent with the known customer profile.

Fact Sheet: Key figures and observations based on 2019 STRs received from the Remote Gaming Operators

The most common reasons for suspicion that led to the submission of an STR or a SAR with the FIAU were:  transactions (46% of the cases), behaviour (21%), identification and verification process and documentation (16%), adverse media (3%) and high-risk jurisdictions involvements (2%).

Some common inconsistencies were reported as follows:

  • transaction activity which is unexplained or is inconsistent with the known customer profile;
  • large volume of deposits which are not in line with customer’s known profile;
  • complex transactions;
  • suspicious narratives or mismatch between the name of the beneficiary and the name of the bank account to be credited;
  • chargebacks; and
  • other general situations relate to large amounts being deposited, withdrawn and/or significant losses registered in a short period, but with no or limited source of wealth or source of funds, information obtained.

Fact Sheet: Strategic analysis on Intelligence presenting an international element

The sample of STRs which included predicate offences conducted abroad had the most common offences observed as fraud, followed by tax crimes, corruption and bribery.

The common denominator triggering suspicion examined in this study were:

  • The customer became uncooperative when requested to provide required details and/or documentation on a transaction or operation;
  • Large volume deposits which are not in line with the customers’ known profile;
  • Unusual or suspicious identification documents or lack of documents;
  • Company and/or transactional structure is unnecessarily complex;
  • Subject persons linked to the subject of STR are adversely known to open sources; or
  • Transfers to, or from, high-risk jurisdictions, without apparent economic business reason/sense.

All three documents provide interesting real-life case studies resulting from STRs submitted by subject persons.

Follow this link to access the documents: https://bit.ly/2GN9JZB