What procedures are to be taken when CDD raises red flags?

During the conduct of CDD, unusual transactions and activities (including attempted transactions and activities) may be identified. Section 18 of the AMLTF Code of Practice requires employees of FIs and DNFBPs to report such instances to the Money Laundering Reporting Officer (“the Reporting Officer”), who is required to investigate those details and determine if a report needs to be made to the Financial Investigation Agency (FIA). This includes where an applicant for business or customer fails to provide sufficient evidence to verify their identity.

Section 17 of the AMLTF Code of Practice stipulates the Reporting Officer’s duty to report all suspicious customers or activities associated with ML, TF or PF to the FIA. Refer to the separate Suspicious Activities Reporting (SAR) FAQs for further guidance.