Sanitised case 9
A local institution filed a SAR based on suspicions arising initially from account activity not being in keeping with expectations, an account set up for personal reasons. The account was being used for third party payments to and from Russia,where the client was based and employed. The client stated these payments wereloans to friends and repayments. He was employed in the industry and should have been aware of his obligations and had refused to comply with updated KYC/CDD.
This client was using his account as a business to avoid the local legislative issues in
place in the jurisdiction he was employed, assisting his clients, which is against what
was originally proposed.
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