Typology relevant when entities are located in areas deemed by the Client
What is High Risk Jurisdiction?
100
Occurs when an entity is transacting with counterparties who are in business lines completely unrelated to that entity.
What is Irregular Business Pattern?
100
Transactions conducted in a short period of time.
What is Activity Burst?
100
When the ultimate originator/beneficiary of funds cannot be ascertained and is unverifiable.
(example: omnibus account)
What is Lack of Transparency?
100
Entities engaged in an industry relative to money laundering.
What is High Risk Business?
200
When the main entity and/or significant counterparties of a case cannot be conclusively identified through available sources and the public domain.
What is Unidentified Entities?
200
Typology that is used when a profile is deemed irregular with the transactions involving the entity. Usually, this is confirmed through an RFI.
What is Customer Profile Inconsistencies?
200
Illegal act of splitting cash deposits or withdrawals into smaller payments to circumvent a Currency Transaction Report ("CTR") threshold.
What is Possible Wire Structuring?
200
Company that is incorporated that, at the time, has no significant assets or operations, usually set up in an offshore jurisdiction, which allows these vehicles to be used for non-legitimate purposes.
What is Possible Shell Company?
200
When an entity maintains a bank account outside of its country of domicile.
What is Inconsistent Address?
300
Even dollar amounts, either on the same day, to or from the same party, or minimal activity during the rest of the period.
What is Round Dollar Amounts?
300
To be used when client has closed the customer account.
What is Closed Account?
300
When you receive an RFI which contains derogatory information, such as unusual activity, or that an R&C will be submitted.
What is Negative RM Response?
300
Entities such as hawala's or other financial institutions who are not licensed to operate in that type of industry.
What is Unregistered MSB?
300
Applies to persons who perform important public functions for a State.
What is Politically Exposed Persons?
400
Can be utilized as a generic typology that encompasses activity that appears unusual but cannot be mapped to one of the other typologies.
What is Flow of Funds?
400
When customer is utilizing personal account for business purposes.
What is Potential Mingling of Funds?
400
No transactions for a significant time period (example: a few months)
What is Lull in Account Activity?
400
Instances when information in the OBI/BBI remittance references state that the funds are B/O of FCC to other individuals/entities.
What is Third Party Remittances?
400
This relates to the instances when a derogatory RFI response is received which states that an R&C was filed by a certain jurisdiction.
What is External Report to Local Regulatory Authority?
500
Negative news identified by Accuity, public domain, or other available sources that is relative to your transactions.
What is Adverse Public Information?
500
When funds are remitted from an entity and subsequently the entity receives funds for the same, or near same amount, in close day intervals.
What is Circular Transactions?
500
Any transactions which have been returned by the funds transfer team because of some underlying circumstance, such as OFAC Sanctions.
What is Rejected Payments?
500
Multiple transactions below $3,000 or $10,000
Frequent transactions carried out by a business customer in apparent efforts to provide sustenance to individuals (FEE FOR LIVING, GOODS FOR PERSONAL USE)
What is Advisory Human Smuggling and/or Human Trafficking
500
Review of account activity identified a pattern where incoming remittances are followed by outgoing remittances in similar amounts to unidentified entities. Usually identified in an RFI response.