AML-2A.2.4
Past version: Effective from 01 Jan 2020 to 30 Sep 2021
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(a) Maintain records (in accordance with Chapter AML-6 of this Module) of all originators information received with an inward transfer; and
(b) Carefully scrutinize inward transfers which do not contain originator information (i.e. full name, address and account number or a unique customer identification number). Capital Market Service Providers 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 (i) the ordering financial 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 (Refer to Paragraph AML-2A.2.5); or (ii) the ordering financial institution and the licensee are acting on their own behalf (as principal).
Added: January 2020