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Monday 25 January, 2021

Indicators Related to the Lawyers Sector

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Customer Related Indicators
  1. The client’s extreme secrecy regarding his identity / the true beneficiary's identity and the funding source.
  2. The client hires an agent or intermediary without a convincing reason.
  3. The client's refusal or reluctance to provide the data and documents required to execute the transaction, or submits false or forged documents.
  4. The client occupies a public position, or has professional or family ties with a person who held a similar job, and they have an unusual special commercial relationship due to the frequency of joint transactions.
  5. The client was convicted of a property crime, is currently under investigation for a property crime, or has ties to criminals.
  6. The client or his partners are connected to terrorism or activities related to financing terror.
  7. The client demonstrates an extraordinary familiarity with the normal standards stipulated in the law regarding determining the acceptable identity of the customer, entering data and reports of suspicious transactions – meaning that he asks repeatedly about the procedures of applying normal standards.
  8. The inappropriateness of a natural person who acts as a director or representative to occupy this position.
  9. A non-resident customer or the customer who does not have an address, has multiple addresses, or has a criminal record that includes fraud or breach of trust.
  10. Companies with nominee shareholders or bearer shares.
  11. The customer is from or in a country known to have insufficient measures to prevent money laundering and terror financing.
  12. The customer is a commercial entity and cannot be found on the internet, and / or uses a public email address such as Hotmail, Gmail, Yahoo, etc.
  13. The customer or a third party contributes a huge amount of cash as a guarantee provided by the borrower / debtor instead of using those funds directly, without a reasonable explanation.
  14. The customer uses multiple bank accounts or foreign accounts without a valid reason.
  15. The client has ties to a legal professional that is guiding him to carry out the transaction, or the transaction is lacking a legitimate or economic reason.
  16. The customer is willing to pay fees higher than usual without a logical reason for that.
  17. The client changes his advisor several times within a short period, or employs multiple legal advisors without a legal reason.
 Transaction Related Indicators
  1. The parties or representatives of the transaction are citizens, residents, registered in a high-risk country, or interconnected without a clear commercial reason.
  2. Ties between family members or parties at work or the company, or any other suspicious circumstances.
  3. The frequent appearance of the same parties in the transactions during a short period, or the age of the parties carrying out the transaction is under the legal age, or are unqualified, without a logical explanation.
  4. Attempts to hide the transaction’s true owner or parties.
  5. The person actually managing the process is not an official party of the transaction nor a party representative.
  6. Businesses that rely on the heavy use of cash.
  7. Funding from a third party either for the transaction or to cover the associated fees / taxes without a clear link or legal explanation for that.
  8. Another company, commercial establishment, or government finances special expenditures.
  9. Postponing the choosing of the payment method to a date close to the time of registration in a country where the method of payment is usually guaranteed in the contract without a logical explanation.
  10. Determining an unusually short repayment period, or repaying mortgage loans repeatedly and noticeably before the originally agreed upon maturity date without a reasonable explanation.
  11. Buying assets with cash and then immediately using them as collateral for a loan.
  12. A request to change the payment procedures previously agreed upon, or providing financing to a borrower who is either a natural or juridical person and not a credit institution, without a reasonable explanation.
  13. The transaction includes an inconsistent amount of private funds, bearer checks or cash, especially if it is not consistent with the person’s socio-economic status or the company's economic position.
  14. Refusing the requested service by one of the lawyers, or if the relationship with another lawyer has been severed.
Geographical Location Related Indicators
  1. The customer is from a country known to have insufficient measures to prevent money laundering and terrorist financing.
  2. Funds that are received or sent to a foreign country without a clear link between the country and the client, or that are sent to high-risk countries.
  3. The transaction’s guarantee is currently in a high-risk country.
  4. Recording an increase in the capital from a foreign country that is unrelated to the company or in a high-risk country.
  5. The company illogically receives very high support regarding capital or in-kind assets when compared to the company's business, size, or market.
  6. Unjustifiable and excessive high or low price fluctuations associated with transferred securities (such as: volume of revenue, trade or business, headquarters, volume).
  7. The existence of huge financial transactions requested by newly established companies when they are not justified with regards to the purpose of establishing the company. 
  8. Making deposits to the legal representative’s account without the presence of actual transactions.
  9. Organized cash deposits in the client's account under the legal limit, then withdrawing funds by transfers or bank check to the legal representative's trust account.