Appendix 2/A: Suspicious Transaction Indicators for Money Laundering

Appendix No. (2/A)
Suspicious Indicators for Money Laundering Transactions:

1- Through financial transactions conducted in cash, taking any of the following forms:

• A financial transaction exceeding its value of twenty thousand Jordanian Dinars or its equivalent in foreign currencies. Financial transactions below this limit are considered as a single financial transaction if the indicators suggest they are interrelated.
• Large cash deposits that do not appear normal, made by a natural or legal person whose apparent commercial activity usually involves checks or other payment instruments.
• A significant increase in cash deposits for any person without a clear justification, especially if these deposits are transferred from the account to an entity that does not appear to have a clear connection with that person within a short period.
• Depositing cash amounts in multiple stages, such that the value of the amount deposited each time is less than the limit stated at the beginning of this Appendix, but collectively they form amounts exceeding that limit.
• Depositing cash amounts in multiple stages such that they form large amounts in total.
• Focusing on cash withdrawals and deposits instead of using bank transfers or other negotiable instruments without a clear justification.
• Exchanging large quantities of small-denomination banknotes for large-denomination banknotes without clear reasons.
• Unusual large cash deposits using ATMs to avoid direct contact with bank staff, especially if those deposits do not align with the business and/or ordinary income of the concerned client and the nature of their activity.
• The client executing several large cash transactions at several branches of the bank, or several persons doing so on behalf of the client on the same day.
• The client bringing stamped (sealed) cash amounts from other banks and refusing to provide the bank with a statement of their account at the bank from which the amount was withdrawn.
• Cash deposits involving counterfeit, worn-out, or old banknotes at high rates.
• The client making sudden and rapid withdrawals of their balances without a convincing or acceptable justification.
• Partners, after receiving a letter from the bank stating the deposit of each partner's share of the company's capital, withdrawing the value of the amount deposited in the account after completing the company registration procedures, which may indicate that the company is a front for purposes other than those registered with the Companies Registrar.
• Company accounts that are funded through incoming deposits and transfers followed by cash withdrawals that do not align with their nature in the same sector.

2- Through individuals' accounts, taking any of the following forms:

• The client holding several accounts and depositing cash amounts in each, such that they form a large amount in total, inconsistent with the nature of their work, except for clients whose nature of work requires holding more than one account.
• Existence of accounts where the nature of transactions executed through them does not align with the nature of the client's activity, such that they are used to receive and/or distribute large amounts for an unclear purpose or unrelated to the account holder or the nature of their activity.
• Holding accounts at several banks located within the same geographical area and transferring the balances of those accounts to one account, and then transferring the accumulated amount outside the Kingdom.
• Depositing third-party checks for large amounts and crediting them to the account holder, inconsistent with the relationship with the account holder or the nature of their work.
• Executing large cash withdrawals from an account previously inactive, or withdrawals executed through it are relatively small, or from an account that received large unexpected amounts from abroad.
• A large number of people depositing amounts into one account without an acceptable explanation.
• The client submitting financial statements about their commercial activity that differ significantly from similar companies operating within the same sector.
• Companies with relatively large activity submitting unaudited financial statements not certified by a legal auditor.
• A company that accepts checks from its customers not making any large cash withdrawals from its accounts in exchange for depositing these checks, indicating the possibility of other income sources.
• A fundamental change in the way the client's account is managed, inconsistent with the client's data.
• Company or institution accounts that show little or irregular activity.
• The value of transactions is inconsistent with the information available about the client, their activity, and their income source at the bank.
• Existence of several accounts at the bank for several individuals who do not have a shared relationship (phone number, PO Box, residence address [apartment], etc.).
• High-risk customers (local/foreign politicians) refusing to declare their positions when opening an account at the bank.
• An insurance company not providing documents proving that the client paid insurance premiums paid to them through the insurance company's account due to the fulfillment of policy payment conditions.
• An insurance company not providing the bank with signed contracts with clients that justify movements to and from the company's accounts.
• The client appearing to have established new banking relationships with a group of banks in preparation for opening a specific account at the bank.

3- Through transfers, taking any of the following forms:

• Transferring deposits in the account directly abroad, whether in a single installment or several installments.
• Transfers of identical amounts (daily, weekly) that form large amounts in total.
• Executing transfers to a person who does not hold an account at the bank using many different payment instruments, each less than the limit stated in the instructions.
• Incoming transfers accompanied by instructions to convert their value into checks and mail them to a person who does not have an account at the bank.
• Issuing transfers for large amounts to countries known as havens for banking or tax secrecy.
• The beneficiary using the value of incoming transfers to their account to purchase various cash instruments immediately upon receiving the value, with the aim of paying another party.
• An account receiving transfers for large amounts that this account has not previously received, inconsistent with the nature of the client's activity.
• The client repeatedly executing external transfers for funds claimed to be of international external source.
• The client depositing bearer instruments into their account and then transferring them to a third or fourth party.
• Executing a non-routine transfer within a package of routine transfers executed as a single transfer (aggregate transfer).
• Transferring large amounts outside the Kingdom or receiving incoming transfers from abroad accompanied by cash payment instructions.
• Transfers issued by an insurance company to clients justified as being for an insurance policy whose payment conditions were fulfilled for the beneficiary.

4- Through safe deposit boxes, taking any of the following forms:

• The client holding several safe deposit boxes without a clear justification.
• Extensive use of safe deposit boxes, which may indicate the client's possibility of holding large amounts of cash in these boxes.
• The client frequently visiting safe deposit boxes before or after making cash deposits less than the limit stated at the beginning of this Appendix.
• An increase in the frequency of the client's visits to safe deposit boxes in a manner that appears strange compared to their previous usual entry rate.

5- Through investment-related transactions, taking any of the following forms:

• Purchasing securities for holding in safe deposit boxes at the bank, with no alignment with the client's activity and financial status.
• The client's lack of interest in ordinary decisions that should be taken regarding investment accounts, such as fees or appropriate investment means.
• The client liquidating a large financial position through a series of small cash transactions.
• The client depositing cash installments, payment orders, traveler's checks, or counter checks for amounts less than the limit stated at the beginning of this Appendix to fund an investment account.
• The client using investment accounts as a tool to transfer funds to external parties, especially to offshore areas.
• Introducing large financial amounts from abroad for investment in foreign currencies or securities when the investment volume is inconsistent with the client's financial status.
• Attempting to make financial transactions appear more complex than necessary through the use of influential terms such as (Hedging, Prime Bank Notes, Stand By commitment, Contracts, Arbitrage).

6- Through credit facilities, taking any of the following forms:

• Applying for facilities for external companies or companies operating in offshore areas, or facilities secured by commitments from external banks or offshore banks.
• The client suddenly repaying a large debt without a clear and reasonable explanation for the source of repayment.
• The client purchasing deposit certificates and subsequently using them as collateral for repaying facilities.
• Obtaining credit facilities secured by cash deposits.
• Obtaining credit facilities against cash guarantee abroad.
• The client unexpectedly transferring the value of the obtained facilities abroad.
• The client repaying debt before the expected time and in amounts greater than expected.
• Requesting facilities against mortgaging assets owned by a third party, where the source of those assets is unknown to the bank or the volume of those assets is inconsistent with the client's financial status.
• The client requesting facilities or arranging financing from third parties where the source of the client's or clients' financial contribution to that financing is unknown.
• Obtaining credit facilities against blocking deposits of a company or companies abroad, especially if they are in countries known for producing and/or marketing drugs.
• Circumstances surrounding the request for credit facilities leading to the bank's refusal to grant these facilities due to doubts about the validity and correctness of the guarantees for these facilities.
• The client submitting financial statements that do not conform to accounting principles.

7- Through trade financing and documentary credits, taking any of the following forms:

• The client requesting commercial financing for export or import of basic goods whose announced prices differ fundamentally and significantly from prices in a similar market.
• Issuing documentary credits or guarantee letters based on the client's request for tenders without existing contracts for projects or for an unusual beneficiary.
• The client changing the name of the beneficiary of the documentary credit shortly before the payment process.
• The client changing the payment location in the documentary credit to an account in another country other than the beneficiary's country.
• The beneficiary of the documentary credits being companies owned by the client or shipping companies owned by the same client.
• The amounts stated in the documentary credit documents submitted by the client to the bank or the customs department do not match the original.

8- Through international banking and financial transactions, taking any of the following forms:

• Acknowledging the identity of a person by external entities located in countries known for producing and/or marketing drugs.
• Building large balances inconsistent with the volume of the client's normal activity and continuous transfer to an account or accounts opened abroad.
• Executing banking transactions related to offshore banking units whose names resemble those of reputable legitimate banking institutions.

9- Through electronic banking services, taking any of the following forms:

• The account receiving several small financial transfers electronically and then executing large transfers in the same way to another country.
• Depositing large installments regularly by various means, including electronic deposit, or receiving large installments regularly from countries known for producing and/or marketing drugs.
• The client requesting to open an account online and refusing to provide the necessary information to complete the account opening or refusing to provide information that would usually entitle them to services and facilities considered by the ordinary client as additional benefits.
• The client using online banking service to transfer between their accounts many times without clear reasons for doing so.

10- Through client behaviors:
The following client behaviors are considered indicators of involvement in illegal operations:

• The client who inquires with the bank about the bank's records, systems, and instructions for the purpose of having sufficient information about money laundering operations and avoiding legal violations regarding them.
• The client who shows dissatisfaction and unwillingness to complete the procedures of a certain financial transaction when they know that it requires reporting the details to the relevant authorities.
• The client who behaves abnormally, such as not taking the opportunity to obtain high interest on a large account balance and being ignorant of the basic facts related to the financial transaction.
• The client with a volatile temperament who refuses to provide the bank with the necessary identity verification documents.
• The client who is still a student and irregularly requests issuing or receiving transfers or exchanging currencies for large, unusual amounts inconsistent with their status.
• The client who is controlled by another person when attending the bank, and the client is unaware of what they are doing, or an elderly person accompanied by a person who has no relation to them when executing the financial transaction.
• The client who offers a sum of money or valuable unexplained gifts to a bank employee and attempts to persuade the employee not to verify identity documents and other documents.
• The client who provides questionable identity verification documents and refuses to provide the bank with their personal information.
• The client who provides the bank with a permanent address located outside the bank's service area or outside the Kingdom.
• The client who refuses to disclose details of their work activities or disclose data, information, or documents related to their institution or company.
• The client whose home phone, work phone, or mobile phone is disconnected.

11- Through bank employee behaviors:
The following bank employee behaviors are considered indicators of involvement in illegal operations:

• A noticeable and sudden increase in the employee's standard of living and spending level inconsistent with their monthly income.
• The employee assisting in executing transactions where the ultimate beneficiary or counterparty is not fully known.
• The employee repeatedly bypassing control procedures and adopting an evasive policy in performing their work.
• The employee exaggerating the credibility, ethics, ability, and financial sources of the client in their reports submitted to the bank's management.
• The bank employee not taking their annual leave or frequently visiting the bank during their leave.
• The employee exploiting their account and granted authorities or position to execute movements that do not conform to the Code of Conduct.
• The employee moving accounts belonging to clients or their relatives through forged powers of attorney / judicial agencies.