INDICATORS FOR RECOGNISING SUSPICIOUS TRANSACTIONS RELEVANT FOR
VOLUNTARY PENSION FUND MANAGEMENT COMPANIES
1. A client - natural person who is a member of a voluntary pension fund is unemployed and
pays contributions for himself/herself based on the membership contract exclusively by paying in
money either through a massive lump-sum payment or successively on monthly, quarterly or six
months basis, that is, in line with the agreed contribution payment plan.
2. A client is a natural person who has made a contract obliging him/her to pay money in the
fund to the benefit of numerous members of the fund who are not connected to the client by any
family ties.
3. A client - a fund member, domestic and foreign national approaching the age of 58, pays in
significant amounts to the voluntary person fund and informs the staff he/she is planning to
withdraw the pooled funds as soon as he/she turns 58 (which is the minimal age limit to be
allowed to withdraw the pooled funds) although a positive trend in the growth of worth of an
investment unit is expected.
4. Clients - contributors - legal persons, employers or organisers pay in significant amounts as
contributions for natural persons approaching the age of 58 and inform the staff these
beneficiaries are planning to withdraw the pooled funds as soon as they turn 58(which is the
minimal age to be allowed to withdraw the pooled funds) although a positive trend in the growth
of worth of an investment unit is expected.
5. Clients - domestic and foreign natural and legal persons - contributors who pay in
contributions to a voluntary pension fund to the benefit of the fund members approaching the
maximum age limit (70 years of age) to be allowed to withdrew the pooled funds from a pension
fund.
6. A client who is a fund member attempts to get the money from the voluntary pension fund
before it turns 58 by submitting documentation on surreally high costs of medical treatment or by
falsifying documentation on permanent working disability, so as to be allowed to withdrew and
dispose of the pooled funds.
7. Payments of contributions to the benefit of a voluntary pension fund members are executed by
a legal person or an employer for whom it has been established, or it is suspected, that it does not
employ the fund members or that the fund members are not its founders or managers.
8. A client who is a fund member or wants to sign a contract with a voluntary pension fund
management company has bad reputation in the country.
9. A client - a fund member - who is a domestic or foreign national pays in contributions to the
voluntary pension fund in his/her own name, or in the name of certain fund members, by sending
transfers from banks in offshore destinations, the countries which do not implement AML/CFT
standards or the countries with strong bank secrecy regulations in force. The lists of such
countries can be found on the website of the Administration for the Prevention of Money
Laundering.
Article 10 Contributions to the benefit of certain members of a fund are paid in by a newly
founded company whose business operations are dubious.