Assignment 6

Task 1.
To open an account at XYZ bank my client needs to provide identification documents (such as passport
number, ID number or country of issuance, source of wealth, explanation for what he needs this account, etc.
Task 2.
Most of the cryptocurrency market are not governed by a central body and because all information about
transaction and beneficiaries is anonymous, nowadays bitcoin and other cryptocurrencies are so famous in
money laundering schemes, such as fraud or terrorism financing.
Task 3.
There are more ways to send money to a sanctioned jurisdiction without having the transfer blocked. First,
legally OFAC can give you a special permission to transfer money, but you must be able to prove that your
funds are not for commercial purposes. Second way can be illegal done using cryptocurrency, online transfers
or offshore. It’s dangerous for criminals to spend a large amount of ill-gotten money due to the possibility that it
could link them to their crimes. So, they attempt to trade it for something just as valuable, such as Bitcoin.
Once the money is converted, the criminals then move it through a series of different financial institutions,
accounts, and other assets in a sanctioned jurisdiction. The idea here is to attempt to put as much space
between themselves and the illegal money as possible, while still retaining assets of the same value. After
they’ve exchanged their illegal funds for what appear to be legal or “clean” funds, they are free to spend them.
Task 4.
Analysing all activities, I didn’t find anything suspicious, only the fact that a user withdrew money in 7 different
currencies looks a little bit suspicious, because this is one of the red flags in money laundering.
Task 5.
After some check up on the account activity of M.M.H I found the last transaction a little bit suspicious (unusual
sum of money), due to this fact I will ask my client why he need to make such transactions and who will getting
the money form this transaction. Perhaps he sold his house or car and gained this money, I will require
documents which can prove the nature of money, etc.
Task 6.
If the customer refuses to provide the documents requested claiming this is against his rights based on GDPR I
will try to convince him that I need these documents to decide about his unusual transaction. When he signed
the contract with bank, he was responsible to provide any required information or documents when bank ask to
do so. If not, I can freeze his account because of suspicious activity or end the relationship.

Task 7.
In case my customer is unsatisfied with the service and wishes to file complaint to the Financial Ombudsman I
will do the same because this is a common right and the fairest way to solve the issue. I’m confident that my
activities were according with the banking system provisions and I treated my client fair during our all
relationship.
Task 8.
- The activity on the account doesn’t match the customer’s profile due the fact that his income it’s around
£20,000 per year and the turnover on the account is £60,000 per 6 moths.
- Red flags are indicators or warning signs that a customer or transaction may be suspicious. The red
flags about this account are:
a) The client is reluctant to provide or refuses to provide information, data and documents
required to enable the transaction’s execution.
 b) Transactions in which assets are withdrawn immediately after being deposited unless the
customer’s business activities furnish a plausible reason for immediate withdrawal.
c) Account was created on the same device as five others (two of them received fraud reports)
d) Account activity is not commensurate with the customer’s known profile (e.g., age, occupation,
income).
e) Using of multiple currencies.
- My customer wants to withdraw the money still left in his account, the appropriate action to take in
relation to this request will be just to not allow it, because purpose to freeze the bank accounts is to
stop the further layering/division of proceeds of crime and to safeguard the proceeds of crime.

Biography:
https://aml-cft.net/library/banks-amlcft-red-flags/
https://www.youtube.com/watch?v=qXQ6lesfwEI