一名學校老師最近在一家主要銀行開設了私人銀行帳戶。該客戶表示年收入為 45,000 歐元,並將她的財富來源列為從親戚那裡繼承的 150 萬歐元。客戶計劃投資每年從不記名債券賺取的 12,000 至 15,000 歐元。客戶經理在開戶前驗證了客戶的身份並將所有上述資訊記錄在帳戶文件中。在對帳戶進行例行審查期間,鑽石經銷商進行了多次電子轉賬,每次轉帳金額超過 500 萬歐元。客戶經理也注意到,每次客戶都會立即將資金轉入香港的銀行帳戶。下列哪一項適合反洗錢專家推薦?
Correct Answer: B
The customer's profile and transactions are highly suspicious and indicative of possible money laundering.
The customer's income, source of wealth, and investment plans do not match with the large and frequent transfers from a diamond distributor, which is a high-risk business sector for money laundering. The customer's transfers to Hong Kong, which is a high-risk jurisdiction for money laundering, also raise red flags.
The anti-money laundering specialist should recommend contacting the competent authority and local law enforcement to report the suspicious activity and cooperate with any investigation. This is in accordance with the FATF Recommendation 20, which states that "If a financial institution suspects or has reasonable grounds to suspect that funds are the proceeds of a criminal activity, or are related to terrorist financing, it should be required, by law, to report promptly its suspicions to the financial intelligence unit (FIU)"1. The other options are not appropriate, as they do not address the urgency and severity of the situation.
References: 1: FATF (2012), International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation, FATF, Paris, France, www.fatf-gafi.org/recommendations.html, p. 19.