FC-11.1.10
(a) Maintain records of all originator 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). 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 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. The period of 2 business days provided to ordering financial institution by the licensees to furnish the originator information is only applicable while undertaking fund transfer (traditional wire transfer) and must not be used in case of transfer of crypto-assets .
Added: January 2024