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2.3.1.2 Cash Deposits

يسري تنفيذه من تاريخ 27/9/2021

Cash-intensive businesses can be expected to make cash deposits, which is legal and a natural fit with their business model. Illicit actors, however, will seek ways to place their illicit cash into the financial system. Illicit actors involved in cash generating crimes frequently need to use a significant portion of the cash they have acquired to pay for the illicit goods they have sold, to purchase additional goods, and to pay the various expenses incurred in acquiring or transporting the goods. As part of the money laundering process, individuals seek to use the proceeds of crimes by disguising the origin of the funds as legitimate economic activities. Terrorists also seek to finance, often through small amounts of cash, terrorist activities without traceability. LFIs should therefore be aware of cash deposits placed into the banking system that involve high-risk customers and/or geographical areas, third parties without a relationship to the customer, and transactions that lack an apparent business purpose. LFIs should, as the case may be, undertake CDD measures on the third party cash depositors transacting in any accounts above the threshold specified in Article 6 of the AML-CFT Decision. LFIs should also obtain appropriate information regarding the source of cash deposited in a customer’s account as well as mandate the use of Emirates ID for cash deposits in ATMs.

 Potential Risk Indicators:
  oLarge cash deposits followed immediately by withdrawals or electronic transfers.
  oLarge cash deposit followed by an immediate request that the money be wired out or transferred to a third party, without any apparent business purpose.
  oFrequent cash deposits by multiple individuals into a single bank account, followed by international wire transfers and /or international withdrawals through ATMs.
  oLarge cash deposit is followed within a short time by wire transfers to high-risk jurisdictions.
  oNumerous cash deposits made in different bank branches over a short period of time.
  oFrequent cash deposits in small amounts, without any apparent business purpose or reasonable grounds.
  oCustomers who use false identification or offer different identifications on separate ccasions