Flashcards: Mastering Suspicious Transaction Identification and Reporting — 24 cartões

Suspicious Transaction — definition?

Unusual activity indicating possible ML/TF/PF involvement.

Grounds for suspicion — include?

Inconsistent profile, large/complex transactions, unverifiable source.

Red Flag — frequent small credits?

Multiple unrelated deposits suggesting structuring.

Regulatory Framework — FATF Recommendation?

Requires reporting suspicious transactions to FIU.

ALPA (2008) — purpose?

Mandates reporting suspicious activities linked to illicit funds.

Predicate Offence — example?

Drug trafficking, corruption, fraud.

Penalty for non-compliance?

Fines up to Rs. 1 million, disciplinary or criminal sanctions.

Tipping Off — prohibition?

Illegal to disclose STR filing to clients or third parties.

Confidentiality law?

Prohibits revealing suspicious activity reports to prevent alerting suspects.

Good faith reporting — protection?

Law shields reporters from liability if done in good faith.

Customer Due Diligence — purpose?

Verify identity and assess risk of clients.

Updating KYC — when?

Periodically or when new info arises.

High-risk customers — action?

Apply enhanced due diligence procedures.

Transaction monitoring sources?

Customer activity, law enforcement inquiries, cross-account analysis.

Red flags at customer desk?

ID refusal, unusual deposits, inconsistent explanations.

Trade Based Money Laundering?

Using trade transactions with misdeclaration or false docs to launder funds.

Indicators of TBML?

Over-invoicing, under-invoicing, suspicious trade patterns.

Loan suspicion — signs?

Inconsistent deposit/withdrawal patterns, use of third parties.

Asset suspicion — signs?

Unusual transaction flows, use of minor accounts, inflated invoices.

Digital transaction risks?

Cyber fraud, anonymous transfers, cross-border misuse.

Suspicious transaction drafting — key?

Clear customer profile, detailed transaction info, grounds for suspicion.

Classification of STRs?

High/medium/low risk, PEP, TBML, aiding prioritization.

Case study — pattern?

Unrelated small credits, rapid withdrawals, high-risk jurisdictions.

Red flag scenario — refusal to ID?

Indicates possible illicit intent or concealment.