Understanding the issue
An anti-money laundering enquiry may involve a bank's request for information, concerns about a transaction or correspondence from an authority. The first task is to identify exactly what has been requested, by whom, and whether the matter concerns routine checks, a restriction or an allegation.
A useful account explains the people involved, the business purpose and the movement of funds without filling gaps with assumptions. Keep the original wording of requests and organise the supporting records so that the questions requiring local legal assessment are easy to identify.
Matters within this area
- Customer verification and information requests
- Beneficial ownership and corporate control
- Transaction purpose and source-of-funds documentation
- Account restrictions and correspondence from authorities
A detail worth knowing
Ownership and purpose both matter
FATF's international standards address customer and beneficial-owner verification, the purpose of business relationships and ongoing transaction scrutiny, including the source of funds where necessary. Countries implement these standards through their own legal frameworks; the exact duties and procedures must be assessed locally.
What to prepare
- Keep the exact bank or authority communication, its date, reference and any stated response deadline.
- Gather relevant ownership records, transaction references and agreements or invoices explaining the business purpose.
- Organise existing records supporting the origin of funds and note any explanations already submitted.
Questions to discuss
- What information has been requested, and which transactions or people does it concern?
- Which existing records explain the ownership, purpose and legitimate origin of the funds?
General information. The applicable law, available procedures and deadlines depend on the jurisdiction and the facts. The team confirms service scope and engagement terms directly.