payments received on the account that reference unknown companies in the instructions indicate a possible attempt to obscure the source or purpose of the funds. This could be a sign of money laundering, tax evasion, fraud, or other illicit activities. Such payments should be referred to AML Investigations for further review and verification of the identity and legitimacy of the companies involved.
FATF Guidance on the Risk-Based Approach for Dealers in Precious Metals and Stones, page 18, paragraph 57: “The dealer should also pay attention to the information provided by the customer on the source and origin of the funds or assets, and verify it where possible. For example, the dealer should be alert to situations where the customer provides vague, incomplete or inconsistent information about the source and origin of the funds or assets, or where the information provided does not match with the customer’s profile or business activity.”
Risk-Based Approach For Dealers in Precious Metals and Stones (DPMS), section “Business-based risk approach”, sub-section “2- Geographical location”: “You must also assess the geographical location of your business and the countries you deal with. You must be aware of the countries that are high-risk or non-cooperative jurisdictions as per the FATF recommendations. You must also consider the countries that are subject to sanctions, embargoes, or similar measures issued by the United Nations, the European Union, or any other relevant organization. You must also be careful of the countries that are known to have significant levels of corruption, organized crime, or terrorist activity.”
What are the Risks of Money Laundering for Precious Metals Dealers?, section “Money Laundering Red Flags for DPMS”, bullet point 4: “The customer provides vague, incomplete, or inconsistent information about the source and origin of the funds or assets.”
