Monday, 30 July 2018

Possible indication of Suspicion under PMLA

 Possible indication of Suspicion:
Identity of client

False identification documents
Identification documents which could not be verified within
reasonable time
Non face to face client
Clients in high risk jurisdiction
Doubt over the real beneficiary of the account
 Accounts opened with names very close to other established
business entities
Receipt back of well come kit undelivered at the address given by
the client
Bounced communication
 Frequent change of name, address and bank and demat account
details.

Suspicious Background

Suspicious backgrounds or links with criminals
Multiple Accounts
 Large number of accounts having a common parameters such as
common partners / directors 1 promoters I address I email address /
telephone numbers, introducer or authorized signatory
 Unexplained transfers between such multiple accounts.

Activity in Accounts
 Unusual activity compared to past transactions
 Use of different accounts by client alternatively
 Sudden activity in dormant accounts
 Activity inconsistent with what would be expected fiom declared
income of Client
Nature of Transactions
 Unusual or unjustified complexity
 No economic rationale
Source of funds are doubtful
 Appears to be case of insider trading
Purchases made on own account transferred to a third party through
an off market transactions through DP account
 Transactions reflect likely market manipulations
Suspicious off market transactions

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