Model Compliance Programme for Accountants.doc

D the permission approval of senior management is

Info icon This preview shows pages 14–17. Sign up to view the full content.

View Full Document Right Arrow Icon
(d) The permission/ approval of senior management is required before establishing a business relationship with a PEP (e)Ongoing monitoring of the relationship with the PEP must be conducted 5.12 Nonresident customer and foreign customers (a)If a business relationship or one-off transaction is conducted with a client (company or person) from another country, contact shall be made with appropriate persons in that country for evidence of the identity of the client before completing the transaction. (b) Where the business relationship involves a foreign client a reference shall be sought from the foreign client's bank. 5.13 FATF’s high risk individuals / entities and Non Cooperative Countries/ Territories (a) All new customers will be referenced against FATF’s list of high risk individuals/ legal entities/ jurisdictions at the time of accepting the client Page | 14
Image of page 14

Info iconThis preview has intentionally blurred sections. Sign up to view the full version.

View Full Document Right Arrow Icon
(b) Existing customers will be monitored on a periodic basis (c) The UN1267 List and any list published by the FIU will be used as reference 5.14 Cross border transactions Accurate and meaningful identification data on originator must be obtained for all domestic and cross-border wire transfers, which shall be kept in a format determined by the FIU. Information accompanying a cross-border transfer shall consist of: (a) the name and address of the originator of the transfer (b)a national identification number or a passport number where the address of the originator of the transfer is not available (c) the financial institution where the account exists (d)the number of the account and in the absence of an account, a unique reference number Page | 15
Image of page 15
6. Reporting Suspicious Activities and Transactions 6.1 The law requires the filing of a suspicious transaction report/suspicious activity report (STR/SAR) with the FIU for any transaction or pattern of transactions that is attempted or conducted for ANY amount which is known or suspected to be suspicious. The following is a list of red flags used to identify suspicious transactions for money laundering: (a) The client cannot provide satisfactory evidence of identity (b) Situations where it is very difficult to verify customer information (c) Situations where the source of funds cannot be easily verified (d) Transactions in countries in which the parties are non-residents and their only purpose is a capital investment (they are not interested in living at the property they are buying (e) Frequent change of ownership of same property in unusually short time periods with no apparent business, economic or other legitimate reason and between related persons (f) Client wants to re-sell Property shortly after purchase at a significantly different purchase price, without corresponding changes in market values in the same area (g) Client wishes to form or purchase a company whose corporate objective is irrelevant to the client’s normal profession or activities, without a reasonable explanation (h) The client sets up shell companies with nominee shareholders and/or directors (i) Client repeatedly changes Attorneys within a short period of time without any reasonable explanation (j)
Image of page 16

Info iconThis preview has intentionally blurred sections. Sign up to view the full version.

View Full Document Right Arrow Icon
Image of page 17
This is the end of the preview. Sign up to access the rest of the document.

{[ snackBarMessage ]}

What students are saying

  • Left Quote Icon

    As a current student on this bumpy collegiate pathway, I stumbled upon Course Hero, where I can find study resources for nearly all my courses, get online help from tutors 24/7, and even share my old projects, papers, and lecture notes with other students.

    Student Picture

    Kiran Temple University Fox School of Business ‘17, Course Hero Intern

  • Left Quote Icon

    I cannot even describe how much Course Hero helped me this summer. It’s truly become something I can always rely on and help me. In the end, I was not only able to survive summer classes, but I was able to thrive thanks to Course Hero.

    Student Picture

    Dana University of Pennsylvania ‘17, Course Hero Intern

  • Left Quote Icon

    The ability to access any university’s resources through Course Hero proved invaluable in my case. I was behind on Tulane coursework and actually used UCLA’s materials to help me move forward and get everything together on time.

    Student Picture

    Jill Tulane University ‘16, Course Hero Intern