Terrorist financing indicators

Automated and manual transaction monitoring shall identify unusual or suspicious activity using risk-based scenarios and thresholds.

Institutions shall file SARs with FinCEN within 30 days of detection (or 60 if no subject identified) for transactions meeting reporting thresholds and indicia.

Financial 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.

A financial institution that suspects or has reasonable grounds to suspect that funds are the proceeds of criminal activity or are related to terrorist financing is required by law to report its suspicion promptly to the financial intelligence unit; the Interpretive Note requires reporting of all suspicious transactions including attempted ones, regardless of amount and regardless of whether they involve tax matters.

Countries implement targeted financial sanctions regimes giving effect to the UN Security Council resolutions on terrorism and terrorist financing, freezing without delay the funds and other assets of persons and entities designated by or under the authority of the Security Council under Chapter VII (resolution 1267 and successors) or designated by the country under resolution 1373, and ensuring that no funds or assets are made available to or for their benefit; the Interpretive Note sets the designation authorities and procedures, the freezing obligations without delay and without prior notice, the prohibitions, the communication of designations, the reporting duties of institutions, the delisting and unfreezing procedures and access to frozen funds for basic expenses.

Systems and controls for monitoring customer transactions for unusual or suspicious activity.

Reporting entities must submit SMRs when suspecting a customer or transaction relates to money laundering, terrorism financing, or other criminal activity. Within 24 hours for terrorism financing; 3 business days for other matters.