Indicators Related to Customer
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The client’s extreme secrecy regarding his identity / the true beneficiary's identity and the funding source.
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The client hires an agent or intermediary without a convincing reason.
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The client's refusal or reluctance to provide the data and documents required to execute the transaction, or submits false or forged documents.
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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.
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The client was convicted of a property crime, is currently under investigation for a property crime, or has ties to criminals.
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The client or his partners are connected to terrorism or activities related to financing terror.
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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.
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The inappropriateness of a natural person who acts as a director or representative to occupy this position.
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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.
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Companies with nominee shareholders or bearer shares.
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The customer is from or in a country known to have insufficient measures to prevent money laundering and terror financing.
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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.
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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.
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The customer uses multiple bank accounts or foreign accounts without a valid reason.
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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.
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The customer is willing to pay fees higher than usual without a logical reason for that.
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The client changes his advisor several times within a short period, or employs multiple legal advisors without a legal reason.
Indicators Related to Transaction
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The parties or representatives of the transaction are citizens, residents, registered in a high-risk country, or interconnected without a clear commercial reason.
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Ties between family members or parties at work or the company, or any other suspicious circumstances.
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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.
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Attempts to hide the transaction’s true owner or parties.
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The person actually managing the process is not an official party of the transaction nor a party representative.
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Businesses that rely on the heavy use of cash.
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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.
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Another company, commercial establishment, or government finances special expenditures.
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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.
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Determining an unusually short repayment period, or repaying mortgage loans repeatedly and noticeably before the originally agreed upon maturity date without a reasonable explanation.
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Buying assets with cash and then immediately using them as collateral for a loan.
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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.
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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.
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Refusing the requested service by one of the lawyers, or if the relationship with another lawyer has been severed.
Indicators Related to Geographical Location
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The customer is from a country known to have insufficient measures to prevent money laundering and terrorist financing.
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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.
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The transaction’s guarantee is currently in a high-risk country.
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Recording an increase in the capital from a foreign country that is unrelated to the company or in a high-risk country.
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The company illogically receives very high support regarding capital or in-kind assets when compared to the company's business, size, or market.
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Unjustifiable and excessive high or low price fluctuations associated with transferred securities (such as: volume of revenue, trade or business, headquarters, volume).
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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.
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Making deposits to the legal representative’s account without the presence of actual transactions.
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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.
