Cross-border activity out of profile
Which scenario compares a customer's international transfers with what the profile on file says they do abroad?
A scenario that places here
example"Cross-border wires inconsistent with customer profile"
Channels it applies to
3 of the 20 in the dictionaryWIN CRD REM
International wires, debit and credit cards and remittance and money transfer: one sector each on the coverage chart, hatched where no scenario reaches it.
Reference lines
held figures- BSA BSA-REC-1 names $3,000 for funds-transfer records on domestic wires, international wires, correspondent accounts and remittance and money transfer. A scenario of this typology starting above it is flagged "above the reporting threshold".
- FATF R.16 INR16.8 names USD or EUR 1,000 for the cross-border de minimis threshold a country may set on international wires and remittance and money transfer. A scenario of this typology starting above it is flagged "above the reporting threshold".
Obligations
4 regimes| Regime | Obligation |
|---|---|
| Bank Secrecy Act and its regulations (31 CFR Chapter X) | BSA BSA-AML-15 Transaction Monitoring |
| FATF 40 Recommendations | FATF R.10 Customer due diligence |
| FATF Recommendation 16, payment transparency, by paragraph | FATF R.16 INR16.9 Cross-border transfers above the threshold: the full information set |
| Anti-Money Laundering and Counter-Terrorism Financing Act (Australia) | AUSTRAC AMLCTF-PartA-TxnMon Transaction Monitoring · AUSTRAC AMLCTF-45 International Funds Transfer Instructions (IFTIs) - Sending · AUSTRAC AMLCTF-46 International Funds Transfer Instructions (IFTIs) - Receiving |
The obligations, quoted
BSA BSA-AML-15 Transaction MonitoringAutomated and manual transaction monitoring shall identify unusual or suspicious activity using risk-based scenarios and thresholds.
Where programmes usually fall short: No model validation; Scenarios not aligned to risk assessment
Source: Bank Secrecy Act and its regulations (31 CFR Chapter X)
FATF R.10 Customer due diligenceFinancial institutions may not keep anonymous accounts or accounts in obviously fictitious names and must, by a principle set out in law, undertake customer due diligence when establishing a business relationship, carrying out an occasional transaction above USD or EUR 15,000 or a payment or value transfer covered by INR.16, when money laundering or terrorist financing is suspected, or when they doubt previously obtained identification data: identify and verify the customer from reliable independent sources; identify the beneficial owner and take reasonable measures to verify that identity, understanding the ownership and control structure of legal persons and arrangements; understand and where appropriate obtain information on the purpose and intended nature of the relationship; and conduct ongoing due diligence and transaction scrutiny consistent with the customer's profile including, where necessary, the source of funds. The extent of each measure follows a risk-based approach; verification takes place before or during establishment of the relationship, or as soon as reasonably practicable after it where risks are managed and business would otherwise be interrupted; an institution that cannot complete CDD does not open the account or perform the transaction, or terminates the relationship, and considers a suspicious transaction report; the requirements apply to new customers and, on materiality and risk, to existing ones. The Interpretive Note sets the risk-based approach, enhanced and simplified measures, the specific measures for legal persons, arrangements and beneficiaries of life insurance, reliance on prior verification and the timing rules.
Where programmes usually fall short: Beneficial owner identified but never verified; Ownership and control structure of corporate customers not understood
Source: FATF 40 Recommendations
FATF R.16 INR16.9 Cross-border transfers above the threshold: the full information setCross-border transfers above the applicable threshold always carry the names of originator and beneficiary; their account numbers where used, or a unique transaction reference number, with the funding institution's name and account where funds are drawn elsewhere; the originator's address (country and town suffice where no standardised postal address exists) and the beneficiary's country and town or nearest alternative; the originator's date of birth where a natural person (year of birth where the full date is unavailable); and, for a legal person originator or beneficiary, the connected BIC, the Legal Entity Identifier or the unique official identifier where one exists.
Where programmes usually fall short: Beneficiary address demanded in full where only country and town are required; Date of birth not held for existing customers
Source: FATF Recommendation 16, payment transparency, by paragraph
AUSTRAC AMLCTF-PartA-TxnMon Transaction MonitoringSystems and controls for monitoring customer transactions for unusual or suspicious activity.
Where programmes usually fall short: No transaction monitoring
Source: Anti-Money Laundering and Counter-Terrorism Financing Act (Australia)
AUSTRAC AMLCTF-45 International Funds Transfer Instructions (IFTIs) - SendingTransfer instructions for funds of any value sent out of Australia must be reported within 10 business days.
Where programmes usually fall short: IFTIs not reported
Source: Anti-Money Laundering and Counter-Terrorism Financing Act (Australia)
AUSTRAC AMLCTF-46 International Funds Transfer Instructions (IFTIs) - ReceivingTransfer instructions for funds of any value received into Australia must be reported within 10 business days.
Where programmes usually fall short: Remittance IFTIs not reported
Source: Anti-Money Laundering and Counter-Terrorism Financing Act (Australia)