• FC-C.2.6

    Categories of customers which may indicate a higher risk include:

    (a) The business relationship is conducted in unusual circumstances (e.g. significant unexplained geographic distance between the financial institution and the customer).
    (b) Non-resident customers;
    (c) Legal persons or arrangements that are personal asset-holding vehicles;
    (d) Companies that have nominee shareholders or shares in bearer form;
    (e) Businesses that are cash-intensive;
    (f) The ownership structure of the company appears unusual or excessively complex given the nature of the company’s business;
    (g) Customer is sanctioned by the relevant national competent authority for non-compliance with the applicable AML/CFT/CPF regime and is not engaging in remediation to improve its compliance;
    (h) Customer is a PEP or customer’s family members, or close associates are PEPs (including where a beneficial owner of a customer is a PEP);
    (i) Customer resides in or whose primary source of income originates from high-risk jurisdictions;
    (j) Customer resides in countries considered to be uncooperative in providing beneficial ownership information; customer has been mentioned in negative news reports from credible media, particularly those related to predicate offences for AML/CFT/CPF or to financial crimes;
    (k) Customer’s transactions indicate a potential connection with criminal involvement, typologies or red flags provided in reports produced by the FATF or national competent authorities;
    (l) Customer is engaged in, or derives wealth or revenues from, a high-risk cash-intensive business;
    (m) The number of STRs and their potential concentration on particular client groups;
    (n) Customers who have sanction exposure; and
    (o) Customer has a non-transparent ownership structure.
    Added: January 2022