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19 Cards in this Set
- Front
- Back
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Customer Risk - Other MSB |
Consumer is another MSB or financial institution that was sanctioned by respective national competent authority for noncompliance with AML/CFT regulations |
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Customer Risk - 4 Unusual "Business" Circumstances |
1) Customer has traveled unexplainable distance to conduct transactions 2) Customer involved in a network 3) Customer owns or operates cash-based business that appears to be a front or shell company 4) Review suggests that customer appears to be intermingling illegal and legal proceeds |
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Customer Risk - PEP |
Customer is a politically exposed person (PEP) or is utilizing his/her family or close associate to transact on their behalf |
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Customer Risk - ID |
Customer is utilizing methods to transact in way that shields their identity - such as using an online platform or providing false ID |
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Customer Risk - Inconsistent ID |
Customer utilizes gives inconsistent information, such as name, address, and identification |
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Customer Risk - Corridor |
Customer is transacting with a an entity in a country in which the customer has no apparent tie or reasonable explanation |
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Customer Risk - Third Party |
Customer is transacting on behalf of a third party but is not disclosing that fact or being controlled by a third party |
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Customer Risk - Sanctions |
Customer is or has been the subject of law enforcement sanctions |
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Customer Risk - Behavioral Red Flags |
Customer is transacting in a manner consistent with criminal typologies or red flags provided in reports from FATF, FinCEN, or law enforcement |
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Product/Services Risk - ID |
Products and services that inherently promote or utilize anonymity of the customer |
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Product/Services Risk - Scope |
Products or services that can readily move value across international borders, such as cash, online money transfers, prepaid cards, money orders, and mobile money transfers |
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Product/Services Risk - Volume |
Products or services that have a high transaction limit |
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Product/Services Risk - Value Transformation |
Products or services that allow for value to be exchanged for a different form of equivalent value, such as the exchange of cash for a prepaid card or money order |
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Agent Risk - Representation |
Agents represent more than one MSB or financial institution |
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Agent Risk - Location |
The agent is located in a higher risk jurisdiction or serves high risk customers |
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Agent Risk - PEP |
Agent is affiliated with a politically exposed person (PEP) |
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Agent Risk - Agent to Agent Activity |
Agent is transacts at an usually high rate with another agent, particularly one located in a high risk jurisdiction |
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Agent Risk - Volume |
Agent possesses a transaction volume that is inconsistent with either overall or relative typical past transaction volume, or is inconsistent with nearby agents |
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Agent Risk - Noncompliance |
Agents have 1) failed to complete training programs 2) are operating sub-standard compliance practices 3) have insufficient customer identification standards 4) have inconsistent record keeping and data recording |
