AML Guidelines (2009 – 2019) – Appendix 1

Appendix 1


  1. Money-Laundering Using Cash Transactions

    • Unusually large cash deposits made by an individual or company whose apparent business activities would normally be generated by cheques and other instruments.
    • Substantial increases in cash deposits of any individual or business without apparent cause, especially if such deposits are subsequently transferred within a short period out of the account and/or to a destination not normally associated with the customer.
    • Clients who frequently pay-in or deposit cash to cover requests for bankers drafts, money transfers or other negotiable and readily marketable money instruments.
    • Clients transferring large sums of money to or from overseas locations with instructions for payment in cash.
  2. Money-Laundering Using Bank Accounts

    • Clients who wish to maintain a number of trustee or clients’ accounts which do not appear consistent with their type of business, including transactions which involve nominee names.
    • Reluctance to provide normal information when seeking to retain the professional services of Corporate Capital (Asia) Group, providing minimal or fictitious information or providing information that is difficult or expensive for Corporate Capital (Asia) Group to verify.
    • Companies’ representatives avoiding contact with Corporate Capital (Asia) Group.
    • Clients who maintain an unusually large number of accounts for the type of business they are purportedly conducting and/or use inordinately large number of fund transfers among these accounts.
    • An account operated in the name of an off-shore company with structured movement of funds.
  3. Money-Laundering Involving Off-Shore International Activity

    • Clients introduced by an overseas client based in countries where production of drugs or drug trafficking may be prevalent.
    • Clients who make regular and large payments, including wire transactions, that cannot be clearly identified as bona fide transactions to, or receive regular and large payments from, countries which are commonly associated with the production, processing or marketing of drugs.
    • Numerous wire transfers received in an account but each transfer is below the reporting requirement in the remitting country.
    • Clients sending and receiving wire transfer to/from financial haven countries, particularly if there are no apparent business reasons for such transfers or such transfers are not consistent with the Clients’ business or history.