FC-C.2.6
Categories of customers which may indicate a higher risk include:
(a) The business relationship is conducted in unusual circumstances (e.g. significant unexplained geographic distance between the financial institution and the customer).
(b) Non-resident customers;
(c) Legal persons or arrangements that are personal asset-holding vehicles;
(d) Companies that have nominee shareholders or shares in bearer form;
(e) Businesses that are cash-intensive;
(f) The ownership structure of the company appears unusual or excessively complex given the nature of the company’s business;
(g) Customer is sanctioned by the relevant national competent authority for non-compliance with the applicable AML/CFT/CPF regime and is not engaging in remediation to improve its compliance;
(h) Customer is a PEP or customer’s family members, or close associates are PEPs (including where a beneficial owner of a customer is a PEP);
(i) Customer resides in or whose primary source of income originates from high-risk jurisdictions;
(j) Customer resides in countries considered to be uncooperative in providing beneficial ownership information; customer has been mentioned in negative news reports from credible media, particularly those related to predicate offences for AML/CFT/CPF or to financial crimes;
(k) Customer’s transactions indicate a potential connection with criminal involvement, typologies or red flags provided in reports produced by the FATF or national competent authorities;
(l) Customer is engaged in, or derives wealth or revenues from, a high-risk cash-intensive business;
(m) The number of STRs and their potential concentration on particular client groups;
(n) Customers who have sanction exposure; and
(o) Customer has a non-transparent ownership structure.
Added: January 2022