EXERCISES – DAY 2
KEY INDICATORS OF MONEY LAUNDERING AND TERRORIST FINANCING AND ACTIVITIES
1. John is the owner of a cold store. He opens a bank account with your bank and deposits
cash in his account almost on a daily basis.
Is this suspicious? Why
2. Jack has an account with your bank. He works in a departmental store. Over a period of
one month, Jack has been depositing cash in his personal account and the amount never
exceeds BD 6,000. After a month, he requests that the entire amount be transferred to
a bank account in Geneva.
a. Is this suspicious? Why?
b. What are the suspicious transaction indicators?
c. How will your deal with this account?
3. You work as a teller in your bank. A customer, who has recently opened an account with
your bank walks in with a large amount of cash and on being questioned about the
source, he says that he has withdrawn it from his account in another bank and produces
the withdrawal slip as source of funds. On further questioning, he gets angry and in
order to appease him, you process the transaction.
a. Is this suspicious?
b. What should you have ideally done?
c. What steps should you take?
4. You work as a teller in a bank. A customer who has been banking with you for over a
year now approaches you and hesitatingly puts forth a proposal. In the proposal he says
that he has taken a new job which requires him to be out of the country for more than
one year and hence it would be great if you could help him by opening a bank account in
your name which his family members could use and also that you could help him with
his business transfers etc.
a. How would you react to this request?
b. Is this transaction in anyway suspicious?
c. What will be your further steps?
5. You are the loan officer of your bank. Bob, a customer approaches you for a loan. He
says that his only objective is procuring the loan and he is willing to pay a higher interest
if necessary. He also says that he will be able to give a guarantee from a bank located in
Cayman Islands.
a. Any indicators?
b. If yes, what are the suspicious indicators?
c. How would you deal with this situation?
6. ‘Rick’ ran his own drug trafficking operations. He used several methods to launder the
proceeds. Cash shipments arrived by boat or plane and were promptly placed by
‘couriers’ into a range of bank accounts. The funds were then transferred to personal
accounts of overseas intermediaries who would then send it back to the country. He
would then use this funds and buy real estate etc., using lawyers, real estate agents etc.
a. Identify the three different phases of money laundering here,
b. Identify some of the suspicious transaction indicators
c. ‘Couriers’ in the above example can be called ____________________
7. Depositing cash into accounts via tellers, ATMs is an example of ___________________
8. A customer approaches your bank and opens a safe deposit locker. He frequently visits
the safe deposit locker over the next few weeks. He evades questions and then within a
month vacates safe deposit locker.
a. Is this a ground for suspicion?
b. If yes, what could this be?
9. A customer owns a house and he sells the house and makes a profit of BD 15,000. He
then deposits the amount in three smaller amounts (4,500, 5,500 and 5,000) in three
different accounts in his wife’s name, his daughter’s name and his name. He clearly
explains the source of funds(with proof of requisite documents) as the sale of house and
also gives reason that he wants to distribute the sale proceeds equally between the
three of his family members.
a. Is this a suspicious transaction?
b. If not, set out the reasons why this is not suspicious.