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2.1.3. Cross-Border Movement

يسري تنفيذه من تاريخ 1/8/2022

One of the principal features of many NPPS is that they can be used globally for making payments or transferring funds. While the usefulness of cash and cheques is limited outside the jurisdiction where they were issued, many PPS are internet-based services and specialize in conducting transfers between countries and currencies. For example, a UAE bank that offers checking accounts to UAE residents may have no ATMs or branches outside the UAE. But, if users link their accounts to global or regional payment apps, they can conduct transactions with persons over the world and can use their smartphone as a payment instrument in countries where the bank has no presence, thus introducing new geographical exposure potentially to high-risk countries. And unlike cross-border wires, which carry full identifying information, the bank will frequently only see the customer’s transactions with the payment network itself, rather than their location or ultimate destination. Many illicit finance schemes involve the cross-border movement of funds. Criminals may seek to finance terrorism in other countries, move funds out of sanctioned jurisdictions, or evade the attention of law enforcement in the jurisdiction where a proceeds-generating offense was committed. PPS that allow or facilitate cross-border movement of funds may therefore be particularly attractive to illicit actors.