Registered members, participants, special purpose users, and trading houses and their authorized agents, and/or portfolio managers as appropriate may wish to make additional enquiries in the following circumstances:
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A personal client for whom verification of identity proves unusually difficult and who is reluctant to provide details. |
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A corporate or trust client where there are difficulties and delays in obtaining copies of the accounts or other documents of incorporation. |
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A client with no discernible reason for using your service, e.g. clients with distant addresses who could find the same service nearer to their home base, or clients whose requirements are not in the normal pattern of your business and could be more easily serviced elsewhere |
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An investor introduced by an overseas bank, affiliate or other investor, when both investor and referrer are based in countries where production of drugs or drug trafficking may be prevalent. |
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Any transaction in which the counterpart to the transaction is unknown. |
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| A. |
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A large number of security transactions across a number of jurisdictions. |
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Transactions not in keeping with the investor’s normal activity, the financial markets in which the investor is active and the business in which the investor operates. |
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Buying and selling of a security with no discernible purpose or in circumstances which appear unusual, e.g. churning at the Client’s request. |
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Low-grade securities purchased in an overseas jurisdiction, sold elsewhere, with the proceeds used to purchase high-grade securities. |
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Bearer securities held outside a recognized custodial system. |
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| B. |
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A number of transactions by the same counterpart in small amounts of the same security, each purchased for cash and then sold in one transaction, the proceeds being credited to an account different from the original account. |
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Any transaction in which the nature, size or frequency appears unusual, e.g. early termination of packaged products at a loss, especially where cash had been tendered and/or the refund cheque is to a third party. |
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Transactions not in keeping with normal practice in the market to which they relate, e.g. with reference to market size and frequency, or at off-market prices. |
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Other transactions linked to the transaction in question which could be designed to disguise money and divert it into other forms or to other destinations or beneficiaries. |
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| A. |
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A number of transactions by the same counterpart in small amounts of the same security each purchased for cash and then sold in one transaction. |
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Large transaction settlement by cash. |
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Payment by way of third party cheque or money transfer where there is a variation between the account holder, the signatory and the prospective investor, must give rise to additional enquiries. |
| B. |
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Settlement to be made by way of bearer securities from outside a recognized clearing system. |
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Allotment letters for new issues in the name of persons other than the Client. |
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| C. |
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Payment to a third party without any apparent connection with the investor. |
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Settlement either by registration or delivery of securities to be made to an unverified third party. |
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Abnormal settlement instructions including payment to apparently unconnected parties. |
