FC-3.1.4
Past version: Effective from 01 Oct 2007 to 31 Mar 2011
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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 sending 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 sending institution and the licensee are acting on their own behalf (as principals).
October 07