Money Service Business Insights - ComplyAdvantage https://complyadvantage.com/insights/industry/money-service-business/ Better AML Data Mon, 10 Feb 2025 10:43:01 +0000 en-US hourly 1 Payset boosts analyst efficiency through transaction monitoring alert prioritization https://complyadvantage.com/insights/payset-boosts-analyst-efficiency-through-transaction-monitoring-alert-prioritization/ Thu, 22 Jun 2023 11:11:18 +0000 https://complyadvantage.com/?p=71951 E-money institution (EMI) Payset offers diverse payment solutions, from multi-currency accounts and B2B wallets to currency exchanges and – soon – debit cards. Established in 2018, the company aims to bring financial services up to speed with modern business requirements […]

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E-money institution (EMI) Payset offers diverse payment solutions, from multi-currency accounts and B2B wallets to currency exchanges and – soon – debit cards. Established in 2018, the company aims to bring financial services up to speed with modern business requirements by mitigating the challenges associated with cross-border transactions and currency exchange. 

To combat evolving threats associated with the various sectors Payset serves, the company needed a transaction monitoring solution to evaluate risks associated with a client’s account and specific transactions. Additionally, the solution would need to perform pattern-level analysis across a range of data sets and timelines simultaneously and be able to immediately suspend all movement of funds on a client account as required.  

“To better identify suspicious activity and understand the complete flow of illicit funds, we required a solution that would allow us to view and assess previously unseen connections between different accounts. We also wanted the ability to instantly ‘blacklist’ specific counterparties and their external bank accounts to prevent them from being used in future transactions by the same and other clients.” 

– Adam Mackulin, Head of Compliance & MLRO at Payset

From seamless integration to sandbox

After partnering with ComplyAdvantage, Payset’s in-house development team collaborated with their appointed implementation manager to integrate the company’s data into its new transaction monitoring platform seamlessly. Following this, Payset was able to utilize ComplyAdvantage’s sandbox environment, where real-life transaction monitoring data could be screened to ensure any proposed changes were effective before altering the configuration of the live platform. Once live, Payset’s dedicated customer success manager provides ongoing expert guidance, ensuring compliance operations are aligned with wider business goals. 

In addition to the quick and efficient implementation process, Payset partnered with ComplyAdvantage due to its wide-ranging transaction monitoring rules library. The compliance team could deploy these individually and collectively within the company’s designated customer risk segments, meaning Payset can now take more of a risk-based approach in its analysis of transaction monitoring data.

“The friendly and accommodating technical support team is another reason we partnered with ComplyAdvantage. Our dedicated account manager has taken the time to really understand our business and what we are trying to achieve. They always go above and beyond in responding quickly and effectively to any queries or issues we may have.”

– Adam Mackulin, Head of Compliance & MLRO at Payset

Tailored fraud detection

With ComplyAdvantage’s Fraud Detection solution, Payset is now able to more effectively handle scenarios that pose a particular threat in light of the company’s offerings and the sectors it serves. These include:

  • Smurfing
  • Payment fraud
  • Business trading fraud
  • Financial investment fraud

Mackulin also noted the solution’s capability to detect transactions inconsistent with a customer’s risk profile, stated business model, and flow of funds presented during the onboarding stage. By implementing ComplyAdvantage’s advanced behavioral analytics, Payset can detect unexplained and inconsistent account activity and map out associations between multiple client accounts and counterparties. 

Efficiency gains

With ComplyAdvantage, Payset has experienced an improvement in the efficiency and effectiveness of its compliance team. In keeping with the company’s risk-based approach to compliance, the transaction monitoring alert process has allowed Payset analysts to prioritize and focus on the cases that require the most immediate and detailed attention. “We can now easily identify tasks and assign which ones need to be analyzed live or in retrospect,” said Mackulin.  

Additionally, thanks to ComplyAdvantage’s built-in report generation and data analysis tools, Payset can quickly summarize and assess its performance against various metrics. This information is then incorporated into the company’s senior management discussions to inform future strategy and decision-making.

Looking forward, Payset can update its platform in keeping with its ever-evolving transaction monitoring processes and working procedures. As the company’s client numbers and transaction volumes continue to grow, Payset is confident it has invested in a scalable solution and a long-standing partnership that will grow and adapt in tandem.

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Securing and maintaining a healthy banking relationship: A guide for MSBs https://complyadvantage.com/insights/securing-and-maintaining-a-healthy-banking-relationship-a-guide-for-msbs/ Wed, 24 May 2023 12:01:19 +0000 https://complyadvantage.com/?post_type=resource&p=71490 Obtaining banking services as a Money Service Business (MSB) or fintech providing services similar to an MSB can be challenging. We’ve created this guide to help you achieve this goal by drawing on the experience of our regulatory and compliance experts, in-house practitioners who have advised MSBs and fintechs.

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Regulations for virtual asset service providers (VASPs) in Hong Kong https://complyadvantage.com/insights/aml-regulations-vasp-hong-kong/ Thu, 15 Apr 2021 14:11:05 +0000 https://complyadvantag.wpengine.com/?post_type=kb-post&p=48910 As a gateway to China, Hong Kong is an important financial destination for businesses across APAC and the world, including numerous fintech service providers dealing in virtual assets such as cryptocurrency. Hong Kong’s regional and global status also makes it […]

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As a gateway to China, Hong Kong is an important financial destination for businesses across APAC and the world, including numerous fintech service providers dealing in virtual assets such as cryptocurrency. Hong Kong’s regional and global status also makes it a target for criminals seeking to misuse its financial system to carry out illegal activities such as money laundering and terrorist financing.

To manage the threat posed by virtual assets to the financial system, the Hong Kong Financial Services and Treasury Bureau (FSTB) recently moved to regulate virtual asset service providers (VASP), including cryptocurrency exchanges. Under proposed new VASP AML rules, Hong Kong will extend existing AML/CFT rules as part of a proposed new regulatory regime: accordingly, Hong Kong firms that deal in virtual asset services should understand the new regulatory landscape and how their compliance obligations may change.

VASP AML regulations in Hong Kong

Hong Kong’s existing AML regime is primarily set out in two main articles of legislation, the Anti-Money Laundering and Counter Terrorist Financing Ordinance (AMLO) and the Banking Ordinance, which require firms to put risk-based AML measures in place and to observe certain record-keeping and reporting obligations. In practice, this means implementing suitable customer due diligence measures based on the level of risk they present and monitoring their transactions throughout the business relationship based on their risk profiles. 

Hong Kong’s AML regulations also extend to virtual asset and cryptocurrency providers. In 2019, the Securities and Futures Commission (SFC) introduced the 2019 Regulatory Framework which outlined the risks associated with virtual assets and introduced a licensing process for VASPs that met robust regulatory criteria. The Framework operates on a voluntary, opt-in basis and is limited in scope since it applies only to products regulated under Hong Kong’s Securities and Futures Ordinance, which focuses on ‘traditional’ assets such as stocks, bonds, futures contracts, and funds (and services related to these products). The Framework does not cover platforms that trade only in non-security virtual assets, which means popular cryptocurrencies such as Bitcoin fall outside its regulatory scope. 

To address the limitations of the 2019 Regulatory Framework, FSTB recently proposed a new licensing regime that will apply to all VASPs including virtual asset exchanges.

2021 VASP AML regulations

In November 2020, the FSTB began a consultation period on a proposed new regulatory framework for VASPs. The consultation period ran until 31st January 2021 and a bill is expected to be introduced at some point in 2021 via an update to AMLO. The proposed regime will introduce a requirement for all VASPs in Hong Kong to obtain an SFC license, and will cover any firms that buys, sells, or exchanges virtual assets or that controls virtual assets as part of its business. 

Key highlights of the proposed VASP AML regulatory framework include:

  • Comprehensive regulatory powers for the SFC including the power to assess, monitor and investigate cryptocurrency exchanges and VASPs. 
  • Cryptocurrency exchanges licensed under the regime will have to adhere to the same regulatory and supervisory standards as traditional financial service providers. 
  • The new regulations will apply only to centralized cryptocurrency exchanges (those operating under a central authority). Decentralized cryptocurrency exchanges will continue to be regulated under the opt-in regime. 
  • Licensed cryptocurrency exchanges will only be able to serve professional investors. Retail investors may have to use decentralized exchanges in order to continue performing cryptocurrency transactions.

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VASP licensing compliance

Under the proposed regime, in order to obtain a VASP license from the SFC, cryptocurrency firms must:

  • Be locally incorporated within Hong Kong.
  • Appoint 2 officers who will be personally responsible for overseeing compliance. 
  •  Pass a ‘fit and proper’ test that involves criminal background checks, AML/CFT performance history, and financial standing. 

Similarly, licensed VASPs must meet a range of conditions that are applicable in addition to existing anti-money laundering regulations:

  • Professional investors: The restriction of licensed VASP services to professional investors means individuals with portfolios of HK$8 million or more, corporations with portfolios of HK$40 million or more, or licensed institutions such as banks and broker-dealers.
  • Financial and business soundness: Licensed VASPs must demonstrate they have adequate financial resources (a minimum amount has not yet been specified) and can operate their business in a prudent and sound manner. 
  • Risk assessment: VASPs must conduct appropriate assessments of the AML/CFT risk that their customers present. 
  • Record-keeping and reporting: VASPs must comply with relevant record-keeping and reporting, audit, and disclosure requirements.

VASP AML compliance

The proposed VASP licensing regime in Hong Kong will be implemented in addition to AMLO, which requires firms to put a range of risk-based VASP AML/CFT controls in place, including:

  • Customer due diligence: VASPs should establish and verify the identities of their customers prior to commencing business relationships. The CDD process should involve names, addresses, dates of birth although, in a cryptocurrency context, digital identifiers such as scans of official documents and biometric information may also be necessary. 
  • AML Transaction monitoring: VASPs should monitor the transactional behavior of their customers in order to spot activity that does not match their established risk profile and that could indicate criminal activity. 
  • Screening and monitoring: VASPs should screen their customers against international sanctions and watchlists, for politically exposed person (PEP) status, and for their involvement in adverse media stories.
  • Smart technology tools: Given the vast amount of digital transaction data involved in digital regulatory compliance, VASPs should seek to implement a suitable technological solution to meet their AML/CFT obligations. 

Smart technology solutions, including artificial intelligence and machine learning systems bring automated speed, efficiency and accuracy to compliance processes, and reduce the prospect of costly human error. As an added benefit, smart technology also allows firms to adapt to a changing regulatory landscape such as the proposed VASP AML regime to be introduced in Hong Kong in 2021, and to emergent criminal methodologies.

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AML and eWallets: How to mitigate risks and comply with regulations https://complyadvantage.com/insights/aml-ewallets/ Fri, 17 Jul 2020 08:50:23 +0000 https://complyadvantag.wpengine.com/?post_type=kb-post&p=38638 An eWallet, or digital wallet, is a software-based system that holds users’ payment information and can be used to pay for goods and services, either online or in person with a mobile device.  The global use of eWallets has grown […]

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An eWallet, or digital wallet, is a software-based system that holds users’ payment information and can be used to pay for goods and services, either online or in person with a mobile device. 

The global use of eWallets has grown rapidly, with offerings from established financial and technology brands alongside newer startups. According to some estimates, eWallets will account for 50 percent of e-commerce transaction value in 2025, up from 40 percent in 2021, while 60 percent of the world’s population will be using some form of digital wallet by 2026

While eWallets’ speed and convenience give them obvious consumer appeal, they can also be exploited for criminal use without effective anti-money laundering and countering the financing of terrorism (AML/CFT) controls in place.   

How are eWallets used by criminals?

eWallets are often used for high transaction volumes, and providers are expected to offer instant payments. These features make them vulnerable from an AML/CFT perspective. 

Money launderers can use eWallets to make payments to and from multiple accounts in a short period of time, creating increasingly complex transaction chains and making it harder to trace the source of the laundered funds. This extends to cross-border transactions: while digital wallets can make it easier to send money internationally, this risks regulatory arbitrage, where criminals exploit jurisdictional differences in regulation to evade detection. 

This means eWallets offer new channels for established money laundering typologies, such as:  

  • Structuring: Splitting large transactions into several smaller ones to avoid triggering alert thresholds. 
  • Money mules: Recruiting individuals to hold or transfer money on behalf of criminals. 
  • Prepaid card money laundering: Some prepaid cards do not require banking or other identifying information to be used. This means criminals can add money to them and then use the cards to make purchases, introducing illicit funds into the financial system. 
  • Virtual asset money laundering: The anonymity offered by cryptocurrencies compared to traditional banking makes them an attractive option for money launderers. eWallets linked to virtual asset service providers are therefore at risk of misuse. 
  • Money laundering through crowdfunding platforms: This entered the spotlight in 2024, in part thanks to the use of fiat and cryptocurrency crowdfunding donations in terrorist financing, typically channeled through accounts and eWallets in third countries. 

AML regulations around eWallets

Like all payment firms and other financial institutions (FIs), eWallet service providers are subject to comprehensive AML regulations. The details of these vary according to jurisdiction, and you should consult your local regulatory obligations, but key examples globally include: 

These regulatory regimes, and most others, derive largely from the Financial Action Task Force’s (FATF) International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation, or ‘40 Recommendations’. These set international expectations for AML controls and revolve around a set of essential principles: 

There are also regulations in force specifically for the payments sector. These cover all operational requirements, not just AML, but typically spell out conditions around internal controls like CDD, payment screening, and transaction monitoring. Examples include: 

Given that non-compliance with these regulations can result in significant fines or other enforcement actions, as well as reputational damage, you should make sure your firm has procedures in place to deal with any AML threats you face.

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How to comply with eWallet AML regulations

In 2023, a European Banking Authority (EBA) report found that many payments firms’ AML controls were not proportionate to the inherently high levels of risk they face. If you work in a smaller or newer firm, investing strategically in solutions with machine learning (ML) capabilities can be a highly efficient way to match larger businesses’ longer-standing and resource-intensive compliance infrastructures. In particular, when implementing your compliance program, you should: 

  • Know the risks to watch out for: To satisfy regulators, you should conduct in-depth risk assessments that go beyond box-checking exercises. These should consider your product, customer, and geographic risks. For example, the EBA has identified individuals de-risked from the banking sector, including PEPs, as an increasing threat to the payments sector. 
  • Carry out robust CDD: Criminals often seek to conceal their identities and exploit weak eWallet customer onboarding processes. You should ensure your system remains protected by running CDD checks to verify information such as names, addresses, and dates of birth, and screening customers against sanctions lists, watchlists, adverse media, and politically exposed person (PEP) information. 
  • Ongoing customer monitoring: Due diligence should be an ongoing process, rather than a one-time event. To ensure this is the case and support compliance with SEPA ICT rules, your AML solution should be able to update you automatically on changes in customer risk scores, so you don’t have to manually re-screen customers. 
  • Screen payment counterparties: While ongoing CDD minimizes your risk exposure within your customer base, you should screen all payment details, including counterparties and references, to ensure your services are not being used to send money to high-risk entities. 
  • Implement tailored transaction monitoring: While some suspicious activity only becomes apparent over time, real-time transaction monitoring minimizes any delay in detecting these patterns and reporting them to the authorities. You should adapt your transaction monitoring rules and scenarios to the risks you will likely face. This will allow you to pick up on red flags such as repeated transactions just below reporting thresholds, immediate withdrawals or transfers of funds transferred to accounts, or transactions for no clear purpose. 

“If your firm is operating in or exposed to crypto, you should take its potential for exploitation seriously. Given its growing ubiquity in certain aspects of economic and financial crime, your team can not simply shrug off the risks as an overreaction of regulators or the mainstream financial system. You, therefore, need to deploy appropriate AML/CFT measures – robust due diligence, monitoring, and screening – to protect not only your businesses but also the longterm reputation and credibility of the sector. Crypto has much to offer, and this should not be sacrificed out of an unwillingness to take appropriate precautionary measures.”

Iain Armstrong, Regulatory Affairs Practice Lead, ComplyAdvantage

AML compliance solutions for digital payments providers 

Using ComplyAdvantage Mesh for your AML screening and monitoring needs, you can protect your firm and improve regulatory compliance while retaining the smooth customer experience central to digital wallets. Specifically, ComplyAdvantage can empower your compliance analysts with: 

  • Real-time sanctions updates: Bolster your due diligence and payment screening solutions with system-wide updates to sanctions lists in under an hour. ComplyAdvantage sources data straight from regulators using automated systems with expert oversight. 
  • Payment screening with high straight-through processing: Firms using ComplyAdvantage payment screening have experienced up to 60 percent reductions in false positives while being able to process 99 percent of transactions instantly, ensuring compliance and business growth go hand in hand. 
  • AI-powered transaction monitoring: ComplyAdvantage’s transaction monitoring solution comes with an industry-leading library of rules, a self-serve rule builder for full customizability and ML capability to fill in the gaps where existing rules don’t cover unexplained activity. 

Enhance your compliance without compromising payment speed

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What is a money services business (MSB)? https://complyadvantage.com/insights/anti-money-laundering/money-services-business/ Wed, 11 Jul 2018 10:31:37 +0000 https://complyadvantag.wpengine.com/?page_id=17048 Money services businesses provide currency exchange and conversion services for organizations all over the world. Financial institutions that transmit or convert money fall into the classification of ‘Money Services Business’ (MSB). While they provide some of the same services, MSBs […]

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Money services businesses provide currency exchange and conversion services for organizations all over the world.

Financial institutions that transmit or convert money fall into the classification of ‘Money Services Business’ (MSB). While they provide some of the same services, MSBs are not banks. Thanks to the variety of cheaper, more diverse commercial product options available to anyone seeking to convert or transmit money, the term ‘MSB’ now covers a wide range of organizations, including those offering crowdfunding, e-commerce, and cryptocurrency products.

Money services businesses often represent a significant portion of an economy: in the United States, for example, transactions handled by MSBs in 2017 amounted to over $1 trillion. Given the levels of criminal risk associated with the conversion of currency and transmission of money, MSBs are required to follow strict compliance regulations pertaining to the anti-money laundering and counter-terrorist legislation of the territory in which they operate.

With that in mind, employees of financial institutions should aim to understand how MSBs work, and the relevant legislation which may apply when doing business with them.

What does a money services business do?

Money services businesses come in various shapes and sizes, ranging from small, niche-market startups to large enterprise organizations with international footprints. The commercial currency exchange and transfer landscape is evolving, and so businesses that classify as MSBs might include anything from traditional bureau de changes and post offices to the latest innovative smartphone payment app.

Although the term ‘MSB’ varies between territorial jurisdictions, it is generally used to describe any business which engages in the following financial services:

  • Acting as a bureau de change or office of currency exchange
  • The transmission of money (or representation of money)
  • Cashing cheques payable to customers
  • Taking intermediary payments between a payer and a supplier through telecommunication, digital, and IT devices
  • Offering payment services for bills – e.g gas and electricity, or tax payments

From a practical perspective, an MSB might provide a customer with a short-term loan, money for a holiday, cash remittance to family members abroad, or a facility for conducting business with an institution in a foreign location. MSBs may also offer less conventional or emerging financial services, like crowdfunding projects, cryptocurrencies, or other types of online payment.

Money services business AML compliance

Operating a money services business involves compliance with a complex legislative environment, and in particular with anti-money laundering (AML) regulations.

Financial authorities place such a strong focus on MSBs because the nature of the services they offer puts them at particular risk of being used in a financial crime. Amongst a range of possible criminal enterprises, money exchange services are attractive options for money launderers, online scammers, and terrorist groups who may wish to transmit money to affiliates overseas.

Although the specifics of AML obligations vary by jurisdiction, they generally involve developing and implementing an AML policy that corresponds to an institution’s risk profile – along with reporting obligations to authorities. MSBs are a common feature of financial landscapes in every part of the world – examples of global MSB regulators include:

  • The United Kingdom: MSBs must register with either the Financial Conduct Authority or HMRC, depending on the specifics of their business.
  • The United States:  In the United States, MSBs must register with the Financial Crimes Enforcement Network (FinCEN), be reviewed by the Internal Revenue Service (IRS), and comply with any relevant state and federal laws.
  • Canada: Broadly similar to the United States in terms of regulations, MSBs in Canada must register with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
  • Hong Kong: In Hong Kong, MSBs are known as money service operators (MSOs) and are required to apply for a license from the Customs and Excise Department in order to conduct business. MSOs in Hong Kong must abide by the Anti-Money and Counter-Terrorist Financing (Financial Institutions) Ordinance.

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PEP red flags: 7 indicators for suspicion https://complyadvantage.com/insights/politically-exposed-persons/detecting-misuse-financial-system-peps-red-flags-indicators-suspicion/ Wed, 20 Apr 2016 14:50:26 +0000 https://complyadvantag.wpengine.com/?page_id=7692 Many uncertainties and misunderstandings surround politically exposed persons (PEPs). Classifying a client as a PEP is part of the process that enables financial institutions (FIs) and designated non-financial businesses and professions (DNFBPs) to assess the risks related to PEPs. Since […]

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Many uncertainties and misunderstandings surround politically exposed persons (PEPs). Classifying a client as a PEP is part of the process that enables financial institutions (FIs) and designated non-financial businesses and professions (DNFBPs) to assess the risks related to PEPs.

Since 2012, the United Nations Convention against Corruption (UNCAC) Article 52 has significantly impacted FIs’ identification and management of PEPs. This article requires enhanced due diligence (EDD) for PEPs, meaning stricter background checks, verification of wealth sources, and close monitoring of transactions for suspicious activity, expanding on previous regulations by including foreign PEPs and domestic officials, their families, and close associates. 

Of course, being a PEP does not equate to being a criminal or suggest a link to abuse of the financial system. However, as PEPs are higher-risk customers, FIs and DNFBPs must be familiar with the PEP red flags and indicators used to detect such abuse. 

What are 7 PEP red flag indicators?

The Financial Action Task Force (FATF) has developed a list of PEP red flags/indicators to assist in detecting misuse of the financial system by PEPs during a customer relationship. 

Often, matching one or two of these indicators indicates a statistically raised risk of doing business with a particular customer, and several indicators need to be met before grave suspicion is warranted. However, in some cases – depending on specific circumstances – matching just one or more of these indicators could lead directly to suspicion of illegal activity, such as money laundering.

The FATF’s recommended red flags, as outlined in recommendations 12 and 22, are as follows:

 1. PEPs attempting to shield their identity

PEPs know their status may facilitate the suspicion of illicit behavior. With that in mind, they may conceal their true identity through various means to avoid detection, protect unearned assets, or evade legal trouble. Under the FATF’s recommendation, some of the key red flags to watch out for include the following:

  • The use of corporate vehicles to obscure (i) ownership, (ii) involved industries, or (iii) countries.
  • Use of corporate cars without a valid business reason.
  • Use of intermediaries that don’t match with everyday business practices
  • Use of PEP relatives and close associates (RCAs) as legal owners.

2. Suspicious behavior from PEPs 

When liaising with entities and monitoring activity, firms need to stay vigilant regarding a PEP’s movements and general behavior.  In particular, firms should be aware of any unusual inquiries about their AML/CTF policies, alongside uncommon transfers to accounts in different countries. As a result, the FATF encourages firms to monitor the following: 

  • Investigate any inconsistencies between the information provided by entities and publicly available data, such as asset declarations or salaries, as these discrepancies could warrant further investigation.
  • Pay close attention to entities conducting business in your jurisdiction without a clear and justifiable reason – a legitimate business purpose should be readily available.
  • Carefully scrutinize entities that provide inaccurate or incomplete information, as deliberate misinformation is highly suspicious and requires further investigation.
  • Entities who inquire about a firm’s AML/PEP policies, which could signal potential attempts to exploit vulnerabilities.
  • Be cautious of entities seeking services they wouldn’t usually require, as this might suggest attempts to hide assets.
  • Monitor entities who frequently transfer funds to countries with no apparent connection, as these unrelated financial activities raise concerns about potential illicit sources of income.
  • Conduct additional due diligence for entities denied a visa to your country, as entry restrictions might suggest past issues or security concerns.
  • Closely monitor entities from countries with restrictions on foreign account ownership, as country-specific limitations on holding accounts can be a risk factor.

3. The PEP’s position or involvement in business 

While the previous section highlighted behavioral red flags, understanding a PEP’s position and power within their organization adds another crucial layer to the risk assessment. As outlined by the FATF, individuals holding roles with greater control, authority, and influence can be inherently more susceptible to involvement in illegal activities. Here’s why: 

  • Substantial authority over or access to state assets, funds, policies, and operations.
  • Control over regulatory approvals, including awarding licenses and concessions.
  • The formal or informal ability to control mechanisms established to prevent and detect money laundering and terrorist financing (ML/TF).
  • If they (actively) downplay the importance of their public function or the public function they’re associated with.
  • The PEP does not reveal all positions (including ex officio).
  • Access to or control or influence over government or corporate accounts.
  • Own or control financial institutions or DNFBPs, either privately or ex officio.
  • The PEP (partially) owns or controls the financial institution or DNFBP (privately or ex officio) that is a counterpart or a correspondent in a transaction.
  • The PEP is a director or beneficial owner of a legal entity that is a client of a financial institution or a DNFBP.

4. High-risk industries and sectors for PEPs 

Alongside the PEP’s position in their organization, connections with high-risk industries can raise their risk level. FIs and DNFBPs should use national guidance and conduct thorough risk assessments per the FATF’s recommendation 1. While high-risk industries will indubitably vary from country to country, the FATF presents the following as examples of higher-risk sectors in its recommendations 12 and 22:

  • Arms trade and defense.
  • Banking and finance.
  • Businesses active in government procurement (i.e., those whose business is selling to government or state agencies).
  • Construction and (extensive) infrastructure.
  • Development and other types of assistance.
  • Human health activities.
  • Mining and extraction.
  • Privatization.
  • Provision of public goods and utilities.

5. Transaction indicators 

Accurate transaction monitoring is essential as a PEP’s transactions and banking history can reveal a complete overview of their income, spending, and saving activity for any period. The purpose of a transaction, as well as the nature of the business relationship behind it, should be scrutinized, along with the examples below:

  • Private banking.
  • Anonymous transactions (including cash).
  • Non-face-to-face business relationships or transactions.
  • Payments received from unknown or unassociated third parties.
  • Using several separate bank accounts for unknown purposes.
  • Consistent use of rounded amounts that can’t be justified.
  • An account shows a sudden flurry of activity after a dormant period.

6. Products, services, and delivery channels red flags 

Another key indicator, depending on the nature of the PEP, is their connection to certain industries, products, services, transactions, or delivery channels that can be labeled as high-risk and easy to exploit for money laundering or other illicit purposes. Some of these include:

  • Businesses that mainly cater to (high-value) foreign clients.
  • Trust and company service providers.
  • Correspondent and concentration accounts.
  • Dealers in precious metals, precious stones, and other luxurious goods.
  • Dealers in luxurious transport vehicles (such as cars, sports cars, ships, helicopters, and planes).
  • High-end real estate dealers.

7. Country-specific PEP red flags and indicators

As defined by the FATF in recommendation 19, due diligence is vital if a foreign or domestic PEP is from a higher-risk country. Additionally, the FATF also recommends taking the following geographical considerations into account when entering into a business relationship with a PEP: 

  • Foreign or domestic PEPs from countries that have yet to sign or ratify relevant anti-corruption conventions (or otherwise have not or have only insufficiently implemented these conventions), such as the UNCAC and the OECD Anti-Bribery Convention.
  • Foreign or domestic PEPs from countries with mono-economies (economic dependency on one or a few export products), especially if their countries have export control or licensing measures.
  • Suppose a PEP from a high-risk country has control or influence over decisions that aim to address any shortcomings in the anti-money laundering and combating the financing of terrorism (AML/CFT) system. In that case, it can lead to additional risks.
  • Foreign or domestic PEPs from countries that depend on the export of illegal substances, such as narcotics.
  • Foreign or domestic PEPs from countries with high levels of organized crime.

Detect red flags with automated solutions 

With so many red flags to be wary of, manually analyzing a PEP’s financial transactions, wealth sources, and business relationships can be time-consuming and prone to human error. 

Fortunately, advanced AML solutions offer sophisticated tools that empower comprehensive EDD for PEPs. These solutions surpass basic EDD by delving deeper into their finances and finding the true nature of wealth and transactions. 

Even after initial due diligence, continuous monitoring remains crucial – dynamic screening tools can provide a safeguard by automatically monitoring transactions and activities for suspicious patterns or red flags that may indicate money laundering or other financial crimes.

Implementing these solutions can offer significant advantages – streamlined data analysis and automated workflows significantly reduce operational burdens, freeing up resources for your team to focus on strategic tasks.

An easier way to manage PEP red flags

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