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FC-3.1.4

Banks must:

(a) Maintain records (in accordance with Chapter FC-7 of this Module) of all originator information received with an inward transfer; and
(b) Carefully scrutinise inward transfers which do not contain originator 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 an STR, unless (a), the originating institution is able to promptly (i.e. within two business days) advise the licensee in writing of the originator information upon the licensee's request; or (b) the originating institution and the licensee are acting on their own behalf (as principals).
Amended: October 2014
Amended: April 2011
October 07