Inward Transfers
FC-11.1.10
Licensees must:(a) Maintain records of alloriginator information received with an inward transfer; and(b) Carefully scrutinize inward transfers which do not containoriginator information (i.e. full name, address and account number or a unique customer identification number).Licensees must presume that such transfers are ‘suspicious transactions’ and pass them to the MLRO for review for determination as to possible filing of STR, unless theordering financial institution is able to promptly (i.e. within two business days) advise thelicensee in writing of theoriginator information upon thelicensee’s request. The period of 2 business days provided toordering financial institution by thelicensees to furnish theoriginator information is only applicable while undertaking fund transfer (traditional wire transfer) and must not be used in case of transfer ofcrypto-assets .Added: January 2024FC-11.1.11
While undertaking
crypto-asset transfers,licensees must ensure that theordering financial institution transmits theoriginator andbeneficiary information immediately.Added: January 2024