MLR3C10140 - Business sector specific Guidance: Money Service Businesses: Money Transmitters and Money Laundering Risks

The following list, not necessarily in order of importance, sets out factors that might give an indication that the business may be being used for money laundering or terrorist financing.

• The business may transfer funds to overseas customers without checking their identity because of staff ignorance.
• There may not be records of customer identification.
• The business may not identify business relationships.
• There may not be reports of suspicious transactions, for example new customers with no previous relationship with the business looking to undertake large transactions.
• The business sends money to high risk countries.
• The customers of the business include people with a high cash income for example, restaurant owners, taxi drivers, shopkeepers.
• Customers include prominent long-standing members of the community, both in the UK or in their country of origin, and therefore the transmitter is reluctant to question them about the origins of the cash.
• The business fails to maintain a clear audit trail of transactions.
• Records may be kept in a different language other than English.