Unusual Transactions or Customer Behaviour
FC-2.2.5
Where a
licensee's risk-based monitoring systems identify significant or abnormal transactions (as defined in Paragraphs FC-2.2.2 and FC-2.2.3), it must verify the source of funds for those transactions, particularly where the transactions are above the transactions threshold of BD 6,000. Furthermore,licensees must examine the background and purpose to those transactions and document their findings. In the case of one-off transactions where there is no ongoing account relationship, thelicensee must file an STR if it is unable to verify the source of funds to its satisfaction (see Chapter FC-5).Amended: January 2022
October 2010FC-2.2.6
The investigations required under Paragraph FC-2.2.5 must be carried out by the MLRO (or relevant delegated official). The documents relating to these findings must be maintained for five years from the date when the transaction was completed (see also Subparagraph FC-7.1.1 (b)).
October 2010FC-2.2.7
Licensees must consider instances where there is a significant, unexpected or unexplained change in customer activity.October 2010FC-2.2.8
When an existing customer closes one account and opens another, the
licensee must review its customer identity information and update its records accordingly. Where the information available falls short of the requirements contained in Chapter FC-1, the missing or out of date information must be obtained and re-verified with the customer.October 2010FC-2.2.9
Once identification procedures have been satisfactorily completed and, as long as records concerning the customer are maintained in line with Chapters FC-1 and FC-7, no further evidence of identity is needed when transactions are subsequently undertaken within the expected level and type of activity for that customer, provided reasonably regular contact has been maintained between the parties and no doubts have arisen as to the customer's identity.
October 2010
