Trust Office

Recognizing unusual transactions

As a trust office, you are familiar with the practices within your line of business. Whether a transaction is considered unusual depends largely on your professional judgment. Your opinion is consistent with what is considered unusual within your profession. In addition to your judgment, there are situations that are unusual by nature and should therefore be reported.

If a situation arises as described in the examples below (not exhaustive), this is a reason to further examine whether the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses. It is not necessary to determine with certainty that the above-mentioned crimes have been committed. You merely need to have an assumption that the transaction can be related to one of these crimes.
If you believe that the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses, you are required to report this under the subjective indicator.

Red flags – Trust office

• A transfer from the account held in the name of the company, which is administered by the trust office, to the account of the proxy after which the funds are withdrawn in cash by that proxy
• Payments are made through an account of the company, which is managed by the trust office, to other companies (whether or not abroad) without any underlying agreements or invoices
• Unclear relationship between a potential beneficial owner and authorized signatories
• An inexplicable geographic link between the trust office and the client’s location
• The structure of the client’s company is designed in such a way that it is difficult to determine who the ultimate beneficial owner is

Typologies:

Presentations: