This blog is written by Mr. Muneeb Sultan. Please read this blog and provide your valued comments

Indications of potentially suspicious transactions might include:

  • A number of deposits and/or withdrawals just below the monitoring threshold in short succession (often on the same day)
  • An excessive use of wire transfers
  • Transactions with large currency or bearer instruments
  • High value deposits or withdrawals not normally associated with the type of account they flow through
  • Transactions of a secret nature
  • A pattern of deposits followed by similar (and in some instances, the same) amounts being wired to another account or financial institution
  • Transactions being routed through several jurisdictions without apparent business sense

Businesses should establish appropriate risk-sensitive policies and procedures in order to prevent activities related to money laundering and terrorist financing. These could include policies and procedures which provide for:

  • Internal reporting including appointment of an officer (i.e. MLRO) to receive any money laundering reports and a system for making those reports
  • Prevention of use of products favoring anonymity
  • Determination of whether a client is a politically exposed person (i.e. someone who has been entrusted with a prominent public function, or a relative or known associate of that person)
  • Customer due diligence
  • Identification and scrutiny of complex or unusually large transactions, unusual patterns of transactions with no apparent economic or lawful purpose and other activities regarded by the regulated person as likely to be of the nature of money laundering or terrorist financing
  • Record keeping, including details of customer due diligence and supporting evidence for client relationships
  • Internal control, risk assessment and management, compliance monitoring, management and communication

In addition, businesses should take measures to make relevant employees aware of the law relating to money laundering and terrorist finance, and to train those employees in how to recognize and deal with transactions which may be related to money laundering or terrorist financing.

In order to insure compliance is appropriately managed, businesses will need to ensure;

  • Sufficient senior management oversight
  • Appropriate analysis and assessment of risks of clients and works types
  • Systems for monitoring compliance with procedures
  • Methods of communicating procedures and other information to personnel



Muneeb Sultan

November 3, 2020

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