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[ STAFF NOTES ]
Table 2: Case study 2 and scenarios warranting further review
INCLUDE IN REVIEW―
AS POTENTIAL RISK RELEVANT
EXCLUDE FROM REVIEW― NOT RISK RELEVANT
Wire remittances to a remittance agency in the Philippines
Wire remittances to other parts of the Philippines
Multiple wire remittances to the same beneficiary
Wire remittances from customers whose domicile is in Marawi, Lanao del Sur
Multiple wire remittances in a month or over a three to six-month period from the customer (i.e., not consistent with profile and purpose)
Regular wire remittances once a month and almost on or around the same day (e.g., end-of-month remittances when the customers receive their salary from employers in the country of remittance)
Wire remittances from originator with no apparent link to the beneficiary (in terms of name and ethnicity)
Regular wire remittances to the same beneficiary with identical or similar last names and ethnicity (i.e., likely family members)
The AML investigation will distinguish the “normal” and “usual” wire remittances to Marawi or Lanao del Sur from possible instances where the bank’s customers may have supported the Marawi siege. A SAR should be filed by the bank setting out the data analytics and the AML investigation that was undertaken.
Importance of data analytics to law enforcement
In addition to the data analytics undertaken by law enforcement, the private sector contributes to improved law enforcement outcomes by filing quality SARs. Quality SARs can be filed with good data analytics and AML investigation. Law enforcement can share their enriched data as intelligence for FIs to apply and analyze with their own data.
Conclusion
In undertaking data analytics, the FIs must ensure that complete information is available in the MT103s that they send or receive. If incomplete, FIs must insist on obtaining complete originator information. Once they have the data, the FIs ought to apply the same basic AML investigation techniques as those used when reviewing a TM alert, for example:
• What is the relationship between the customer and the counterparty?
• What is the purpose of the wire remittance?
If the purpose of the wire remittance and the relationship with the counterparty are not apparent based on the customer’s profile, the FI ought to inquire with its customers or review similar transactions processed in the past. If substantial red flags remain unaddressed, the FI should file a SAR.
Rosalind Lazar, CAMS, regional AML director-APAC, ACAMS
Zubin Chichgar, CAMS-Audit, head, monitoring & analytics, Standard Chartered Bank
1 “Recommendation 16: Wire transfers,” Caribbean Financial Action Task Force, https://www.cfatf-gafic.org/index.php/ documents/ fatf-40r/382-fatf-recommendation-16-wire- transfers
2 “Combatting Online Child Sexual Abuse and Exploitation Through Financial Intelligence,” Egmont Group, July 2020, https:// egmontgroup.org/sites/default/files/ filedepot/20200901_CSAE%20Public%20 Bulletin.pdf
3 Ibid.
4 For this case study, Philippines is identified as the country receiving the remittances as payments for CSAE. According to the Egmont Report, the Anti-Money Laundering Council’s (AMLC - FIU The Philippines) study on child pornography was a major source for the project.
5 “Ferry bomb to Marawi siege: Philippines’ worst attacks,” The Straits Times, January 27, 2019, https://www.straitstimes.com/asia/ se-asia/ferry-bomb-to-marawi-siege- philippines-worst-attacks
6 “Measures Undertaken by the Philippine Government to Eliminate International Terrorism,” United Nations Office of Legal Affairs, May 29, 2020, https://www.un.org/en/ ga/sixth/75/int_terrorism/philippines_e.pdf
7 If the retail bank’s customers include remittance agencies that remit regularly to the Philippines, then the scope would have to include these customers, and a review undertaken of the source of the funds for their wire remittances to the Philippines.
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