The IBA WGR 2010 - Indicative List of Alert Indicators

The various alerts generated are given above and detailed explanations are available in two sections as given below

The IBA Working Group Report on AML/CFT 2010
Appendix-D
Indicative Alert Indicators for Branches /Departments
SL NO	Alert Indicator	Indicative Rule / scenario
1	CV1.1- Customer left without opening account	Customer did not open account after being informed about KYC requirements
2	CV2.1 - Customer offered false or forged identification documents	Customer gives false identification documents or documents that appears to be counterfeited , altered or inaccurate
3	CV2.2 - Identity documents are not verifiable	Identity documents presented are not verifiable ie.., Foreign documents
4	CV3.1 - Address found to be non-existent	address provided by the customer is found to be non-existent
5	CV 3.2 - Address found to be wrong	Customer not staying at address provided during account opening
6	CV4.1 - difficult to identify beneficial owner	Customer uses complex legal structures or where it is difficult to identify the beneficial owner
7	LQ1.1 Customer is being investigated for criminal offences	customer has subject of inquiry from any law enforcement agency relating to criminal offences
8	LQ2.1 - Customer is being investigated TF Offences	customer has subject of inquiry from any law enforcement agency relating toTF or terrorist activities
9	MR1.1 - Adverse Media report about TF or terrorist activities of customer	Match of customer details with persons reported in social media /open source for criminal offences
10	MR2.1 - Adverse Media report about TF or terrorist activities of customer	Match of customer details with persons reported in local media /open source for terrorism or terrorist activities
11	EI1.1 - Customer did not complete transaction	customer did not complete transaction after queries such source of funds etc..
12	EI2.1 - Customer is nervous	Customer is nervous or Hurried
13	EI3.1 - Customer is over cautioous	customer is over cautious In explaining genuineness of the trnsaction
14	EI2.3 - Customer provides Inconsistent information	customer changes the information provided after more detailed information is required
14	EI2.3 - Customer provides Inconsistent information	customer provides information that seems minimal, possibly false or inconsistent
15	EI3.1 - Customer acting on behalf of a third party	Customer has vague knowledge about amount of money involved in the transaction
		Customer taking instructions for conducting transactions
		Customer is accompanied by unrelated individuals
16	EI3.2 - Multiple Customers working as a group	Multiple customers arrive together but pretend to ignore each other
17	EI4.1 - Customer avoiding nearer branches	Customer travels unexplained distance to conduct transactions
18	EI4.2 - Customer Offers different identifications on different occasions	Customer offers different identifications on different occasions with an apparent attempt to avoid linkage of multiple transactions
19	EI 4.3 - Customer wants to avoid reporting	Customer makes enquiries or tries to convince staff to avoid reporting
20	EI 4.4 - Customer could not explain source of funds	Customer could not explain source of funds satisfactorily
21	EI5.1 - Transaction is unsuccessfully Complex	Transaction is unsuccessfully Complex for its stated purpose
22	EI5.2 - Transaction has no economic rationale	The amounts or frequency or the stated reason of the transaction does not make sense for the particular customer
23	EI5.3 - Transaction Inconsistent with business	transaction involving movement of which is inconsistent with the customer's business
24	EI6.1 - Unapproved inward remittance in NPO	Foreign remittance received ny NPO not approved by FCRA
25	PC1.1- Complaints received from public	Complaints received from public for abuse of account for committing fraud etc..
26	BA1.1- Alert raised by agent	Alert raised by agent about suspicion
27	BA1.2- Alert raised by Other institution	Alert raised by Other institutions, subsidiaries or business associates including cross-border referral

The Watch list (WL), Transaction Management(TM), Typology(TY) and Risk Management System (RM)related alerts are handled at higher level .

The IBA Working Group Report on AML/CFT 2010
Appendix-E
Indicative Alert Indicators for Centralized AML Cell
SL NO	Alert Indicator	Indicative Rule / Scenario
1	WL1.1 Match with UN List	Match of Customer details with individuals/entities on various UNSCR Lists
2	WL1.2 - Match with UAPA List	Match of Customer details with designated individuals/entities under UAPA
3	WL1.3 - Match with other TF List	Match of customer details with TF suspects on lists of Interpol, EU, OFAC, Commercial Lists(World -check , Factiva, LexisNexis, Dun & Bradstreet etc.., ) and other sources
4	WL2.1- Match with other Criminal List	Match of customer details with Criminals on the lists of Interpol, EU, OFAC, Commercial Lists(World -check , Factiva, LexisNexis, Dun & Bradstreet etc.., ) and other sources
5	TM1.1 - High Value cash Deposits in a day	cash deposits greater than INR[X1] for individuals and greater than INR [X2] for non-individuals in a day
5	TM1.1 - High Value cash Deposits in a day	Top[ N] Cash Deposits in a day
6	TM1.2 - High Value Cash withdrawals in a day	Cash Withdrawals greater than INR[X1] for individuals and greater than INR [X2] for non-individuals in a day
6	TM1.2 - High Value Cash withdrawals in a day	Top[ N] Cash Withdrawals in a day
7	TM1.3 - High Value Non-Cash Deposits in a day	non-cash deposits greater than INR[X1] for individuals and greater than INR [X2] for non-individuals in a day
7	TM1.3 - High Value Non-Cash Deposits in a day	Top[ N] Non-Cash Deposits in a day
8	TM1.4 - High Value Non-Cash withdrawals in a day	Non-Cash Withdrawals greater than INR[X1] for individuals and greater than INR [X2] for non-individuals in a day
8	TM1.4 - High Value Non-Cash withdrawals in a day	Top[ N] Non-Cash Withdrawals in a day
9	TM2.1 - High Value cash Deposits in a Month	cash deposits greater than INR[X1] for individuals and greater than INR [X2] for non-individuals in a month
9	TM2.1 - High Value cash Deposits in a Month	Top[ N] Cash Deposits in a Month
10	TM2.2 - High Value Cash withdrawals in a Month	Cash Withdrawals greater than INR[X1] for individuals and greater than INR [X2] for non-individuals in a Month
10	TM2.2 - High Value Cash withdrawals in a Month	Top[ N] Cash Withdrawals in a Month
11	TM2.3 - High Value Non-Cash Deposits in a Month	non-cash deposits greater than INR[X1] for individuals and greater than INR [X2] for non-individuals in a Month
11	TM2.3 - High Value Non-Cash Deposits in a Month	Top[ N] Non-Cash Deposits in a Month
12	TM2.4 - High Value Non-Cash withdrawals in a Month	Non-Cash Withdrawals greater than INR[X1] for individuals and greater than INR [X2] for non-individuals in a Month
12	TM2.4 - High Value Non-Cash withdrawals in a Month	Top[ N] Non-Cash Withdrawals in a Month
13	TM 3.1 - Sudden High Value Transaction for the client	Value of Transaction is more than [z] percent of the previous largest transaction for the client (or client profile)
14	TM 3.2 - Sudden Increase High Value Transaction in a Month for the client	Value of Transaction in a Month is more than [z] percent of the average value transaction for the client (or client profile)
15	TM 3.3 - Sudden Increase in Number of Transaction in a Month for the client	No of Transaction in a Month is more than [z] percent of the average number of transaction for the client (or client profile)
16	TM4.1- High Value transactions in a new account	Transactions greater than INR[X] in newly opened account within [Y] months
17	TM4.2- High activity in a new account	Number of transactions more than [N] in newly opened account within [Y] months
18	TM5.1 - High Value transactions in a dormant account	Transactions greater than INR[X] in a dormant account within [Y] days of reactivation
19	TM 5.2- Sudden activity in a dormant account	Transactions greater than INR[X] in a dormant account within [Y]days of activation
20	TM6.1- High Value Cash transactions inconsistent with Profile	Cash transactions greater than INR[X] by customer with low cash requirements such as Students, Housewife, Pensioners, Wages & Salary Persons and Minor Accounts
21	TM6.2- High Cash activity inconsistent with Profile	Number of Cash transactions greater than INR[X] by customer with low cash requirements such as Students, Housewife, Pensioners, Wages & Salary Persons and Minor Accounts
22	TY1.1 - Splitting of cash deposits just below INR 10,00,000 in multiple accounts in a month	Cash deposits in amounts ranging between INR 9,00,000 to INR 9,99,999.99 in multiple accounts of the customer greater than [N] times in a month
23	TY1.2 - Splitting of cash deposits just below INR 50,000	Cash deposits in amounts ranging between INR 40,000 to INR 49,999/ greater than [N] times in [Y] days
24	TY1.3 frequent cash Deposit just below INR 10,00,000	Cash deposits in amounts ranging between INR 9,00, 000 to INR 9,99,999.99 greater than [N] times in [Y] days
25	TY 1.4 Routing of funds through multiple accounts	Transactions greater than INR [X1] between more than [N] accounts aggregating to more than [X2] on the same day
26	TY1.5 frequent low cash deposits	Cash deposits in amounts ranging between INR [X1] to [X2] on the same day
27	TY 1.6 Frequent Low cash Withdrawals	Cash withdrawals in amounts ranging between INR [X1] to [X2] on the same day
28	TY2.1 - Many to One Fund Transfer	Funds Sent by more than [N] remitters to one recipient
29	TY2.2- One to Many Fund Transfer	Funds Sent by one remitters to more than [N]recipients
30	TY2.3 - Routing of Funds through multiple locations	Routing of Funds through multiple countries or locations
31	TY3.1 customer Providing different details to avoid linkage	Customer provided different IDs or Date of Birth at different instances
32	TY3.2 – Multiple customers working together	Common address /telephone used by multiple unrelated customers
		Common IDs used by multiple customers
		group of Individuals conducting transactions at the same time
33	TY4.1 - repeated small cash deposits followed by immediate ATM	Cash deposits in amounts ranging between INR [X1] to [X2] greater than [N] times in [Y] days followed by immediate ATM withdrawals in different location
34	TY4.2 - repeated small value transfers from unrelated parties followed by immediate ATM Withdrawals	Account to Account transfer (RTGS /NEFT) from unrelated parties in amounts ranging between INR [X1] to [X2] greater than [N] times in [Y] days followed by immediate ATM withdrawals(especially other banks'ATM)
35	TY4.3 - repeated small value inward remittance from unrelated parties followed by immediate ATM Withdrawals	Inward Remittance (especially from high risk courtiers from unrelated parties in amounts ranging between INR [X1] to [X2] greater than [N] times in [Y] days followed by immediate ATM withdrawals (especially other bank's ATMs)
36	TY4.4 - Repeated Small Value withdrawals in sensitive locations	Cash withdrawals in amounts ranging between INR [X1] to [X2] greater than [N] times in [Y] days in locations with known terrorist incidents
37	TY4.5 - Repeated Small Value inward remittance from unrelated parties used for specified activities	Inward Remittance (especially from high risk countries ) used for purchase of communication equipment, tickets, hotel booking etc..,
38	TY5.1 - Majority of repayments in Cash	card repayments greater than INR[X] amount in cash in [Y ]days
38	TY5.1 - Majority of repayments in Cash	Card repayment in cash is greater than [Z]percent of repayments in [Y]days
39	TY5.2 - Large Debit balance in Credit Card	Debit balance in Credit card is greater than INR[x]
40	TY5.3 - Large Value card transactions for purchase of high value goods	card usage greater than INR[X] for Jewelry (MCC5944) in [Y] days
41	TY5.4 - Large Value Cash withdrawals against International cards	Cash withdrawal is greater than INR [X] against international card in [Y] days
42	TY5.5 - Repeated Small Value Cash withdrawals against International cards	Cash withdrawals against international card in amounts ranging between INR [X1] to [X2] greater than [N] times in [Y] days in locations with known terrorist incidents
43	TY 5.6 Large repetitive card usage at the same merchant	More than [N] transactions at same merchant aggregating to more than INR [X] in [Y] days
44	TY7.1 - Repayment of loan in cash	Loan repayments in cash greater than INR[X] in [Y] months
45	TY7.2 - Premature closure of large FDR through PO/DD	Premature closure of large FDR for an amount greater than INR [X] within [N] days and payments by PO/DD
46	TY7.3 - High Number of Cheque Leaves	Greater than [X1] number of cheque leaves issued for Savings Bank account and [X2] number of cheque leaves issued for Current account in a period of [Y] days
47	TY7.4 - Frequent Locker Operations	Number of locker operations greater than [X] times in [y] days
48	RM1.1- High Value transactions by High Risk Customers	High Value transactions greater than INR[X] by High Risk Customers(refer appendix-A)
49	RM1.2 - High Value Transaction in NPO	Cash transactions greater than INR[X] in Trust/NGO /NPO in [Y] days
50	RM1.3 - High value Cash transactions related to real estate	Cash transactions greater than INR[X} related to real estate transactions in [Y] days
51	RM1.3 - High value Cash transactions by dealer in precious metals or stone	Cash transactions greater than INR[X} rby dealer in precious metal, precious stone or high value goods in [Y] days
52	RM2.1 - High Value transactions in product/service with high ML risk	Transactions greater than INR [X] using (Refer appendix-B) product/service with high ML risk
53	RM2.2 - High Value Inward Remittance	Inward Remittance greater than [X]value aggregated in [Y] days
54	RM2.3 - Inward remittance in a new account	Inward remittance greater than [X] value in a new account within [Y] days
55	RM2.4 - Inward remittance inconsistent with client profile	Inward remittance greater than [X]value in [Y] days in account of Students, Housewife, Pensioners, Wages and Salary Person and Minor accounts
56	RM2.4 - Inward remittance inconsistent with a country with high ML risk	Inward remittance greater than [X]involving a country considered to be high risk from the money laundering or drug trafficking perspective(refer Appendix C)
57	RM3.2 - High Value transaction with tax heavens	Inward remittance greater than [X]involving tax havens or countries that are known for highly secretive banking and corporate law practices (refer Appendix C)
58	RM3.3 - High value transaction in a location with High ML Risk	Inward remittance greater than [X] in a location considered to be high risk from the money laundering or drgug trafficking perspective(refer Appendix C)
59	RM4.1 - High value transaction in a location with High TF Risk	Transaction involving a country considered to be high risk from the terrorist financing perspective (refer Appendix C)
60	RM4.2 - Transaction involving a location with High TF Risk	Transaction involving a location considered to be high risk from the terrorist financing perspective (refer Appendix C)
61	RM4.2 - Transaction involving a location with terrorist incident	Transaction involving a location prior to or immediately after a terrorist incident