Indicators Related to Exchange Companies

International Transfer:

Indicators Related to Customer

1. The client does not show any interest in the transaction's amount or commission.
2. Unexpected or frequent changes to the actual beneficiary or to the customer's contact details.
3. The same address is used by the client but with changing the names associated with it, or his lack of knowledge regarding the beneficiary's address and information, or his reluctance to disclose this information.
4. The client indicates that another party will receive the transferred funds on behalf of the beneficiary.

Indicators Related to Transaction

1. There is no clear economic purpose for the transaction, or the transactions do not appear consistent with the customer's current financial status.
2. The transactions are extremely complex and are not compatible to the declared objective.
3. The client evades or refuses the exchange company's attempts to implement the "Know Your Client" model.
4. The client requests performing the exchange transaction at rate exceeding the exchange company’s approved rate, or requests to pay a transaction fee that exceeds the approved fee.
5. The client requests to exchange money for a number of postal payment orders in small amounts to a number of different parties, or requests the conversion of a large foreign currency amount to another foreign currency.
6. The client initiates transactions with other parties in locations that are uncommon for him.

Indicators Related to Geographical Location

The customer receives remittances from a country known for its high crime rates, such as: (corruption, terrorism, or a high production rate of drugs) or is considered a high-risk country, or if he makes transfers to this country.

Currency Exchange:

Indicators Related to Customer

1. The client has intentionally provided false or unclear information, or refuses to provide the necessary information and documents that explain business relations, relevant activity, and funding sources, destinations and transaction purposes, or if he refuses to send any documents from the company to his address, or if he provides contact details that do not match the contact information.
2. The client requests freedom of action that surpasses the usual scope.
3. There are indications that the client has committed acts punishable by the Central Bank of Bahrain or the laws of the Kingdom of Bahrain.
4. The client acknowledges, mentions, or is known to be associated with criminal activities.
5. The client's uncommon curiosity about systems, control mechanisms, internal policies, and monitoring.
6. The client over-justifies or over-explains the transaction, or exaggerates in presenting documents that prove its authenticity.
7. The client is stressed in a manner not consistent with the nature of the transaction.
8. The client tries to build close relationships with the employees.
9. The client uses pseudonyms and a number of similar addresses.
10. The client offers money, rewards, or unusual services to secure services that may appear unusual or suspicious.
11. The client looks around all the time and does not watch the money count.
12. The client is satisfied despite receiving an inappropriate exchange rate.

Indicators Related to Transaction

1. There is no clear economic purpose for the transaction.
2. The transaction is complicated without reason.
3. Exchanging large sums of small denomination banknotes for larger denomination banknotes.
4. Exchanging large sums or making frequent substitutions that are not related to the client's usual activity, or generating large sums of money.
5. Repeated requests from exchange companies to conduct foreign currency buying/selling transactions with amounts slightly less than the permissible transaction limit for a short period of time.
6. The customer requests a currency with large banknote denominations, or buys a currency that is not compatible with his usual operations.
7. It appears that the client does not know the exact amount he is changing.
8. Buying currencies with large amounts of cash, or large exchange operations between foreign currencies, or the frequent exchanging of large amount of cash between different currencies.
9. The Increased frequency of currency exchange transactions over a period.
10. The use of multiple exchange companies by the same person.
11. Requesting to exchange large sums of money from a foreign currency that is not exchangeable or not commonly traded to another foreign currency.