What are Suspicious Transactions under the UAE AML?

Money laundering using cash transactions

1. unusually large cash deposits made by an individual or company whose ostensible business activities would normally be generated by cheques and other instruments;
2. substantial increases in cash deposits of any individual or business without apparent cause, especially if such deposits are subsequently transferred within a short period out of the account and/or to a destination not normally associated with the customer;
3. customers who deposit cash by means of numerous credit slips so that the total of each deposit is unremarkable, but the total of all the credits is significant;
4. company accounts whose transactions, both deposits and withdrawals, are denominated by cash rather than the forms of debit and credit normally associated with commercial operations (e.g. cheques, Letters of Credit, Bills of Exchange, etc.);
5. customers who constantly pay in or deposit cash to cover requests for money transfers, bankers drafts or other negotiable and readily marketable money instruments;
6. customers who seek to exchange large quantities of low denomination notes for those of higher denomination;
7. frequent exchange of cash into other currencies;
8. branches that have a great deal more cash transactions than usual (Head Office statistics detect aberrations in cash transactions);
9. customers whose deposits contain counterfeit notes or forged instruments;
10. customers transferring large sums of money to or from overseas locations with instruments for payment in cash; and
11. large cash deposits using night safe facilities, thereby avoiding direct contact with bank staff.
    

Money Laundering using bank accounts

1. customers who wish to maintain a number of trustee or client accounts which do not appear consistent with the type of business, including transactions which involve nominees;
2. customers who have numerous accounts and pay in amounts of cash to each of them in circumstances in which the total of credits would be a large amount;
3. any individual or company whose account shows virtually no normal personal banking or business related activities, but is used to receive or disburse large sums which have no obvious purpose or relationship to the account holder and/or his business(e.g. a substantial increase in turnover on an account);
4. reluctance to provide normal information when opening an account, providing minimal or fictitious information or, when applying to open an account, providing information that is difficult or expensive for the institution to verify;
5. customers who appear to have accounts with several institutions within the same locality, especially when the bank is aware of a regular consolidation process from such accounts prior to a request for onward transmission of the funds;
6. matching of payments out with credits paid in cash on the same or previous day;
7. paying in large third party cheques endorsed in favour of the customer;
8. large cash withdrawals from a previously dormant/inactive account, or from an account which has just received an unexpected large credit from abroad;
9. customers who together, and simultaneously, use separate tellers to conduct large cash transactions or foreign exchange transactions;
10. greater use of safe deposit facilities and increased activity by individuals; the use of sealed packets deposited and withdrawn;
11. companies’ representatives avoiding contact with the branch;
12. substantial increases in deposits of cash or negotiable instruments by a professional firm or company, using client accounts or in-house company or trust accounts, especially if the deposits are promptly transferred between other client, company and trust accounts;
13. customers who decline to provide information that in normal circumstances would make the customer eligible for credit or for other banking services that would be regarded as valuable;
14. insufficient use of normal banking facilities (e.g. avoidance of high interest rate facilities for large balances); and
15. large number of individuals making payments into the same account without an adequate explanation.

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