Ask the customer appropriate questions

If your staff carries out a transaction or transactions for a customer, bearing one or more suspicious activity indicators then they should question the customer on the reason for conducting the transaction and the identity of the source and ultimate beneficiary of the money being transacted. Staff should consider whether the customer's story amounts to a reasonable and legitimate explanation of the activity observed. If not, then the customer's activity should be regarded as suspicious and a suspicious transaction report should be made to JFIU.

On occasions some of the staff may be reluctance to ask questions of the type mentioned above. Grounds for this reluctance are that the customer may realize that he, or she, is suspected of illegal activity, or regards such questions as none of the questioner's business. In either scenario the customer may be offended or become defensive and unco-operative, or even take his, or her, business elsewhere. This is a genuine concern but can be overcome by staff asking questions which are apparently in furtherance of promoting the services or satisfying customer needs, but which will solicit replies to the questions above without putting the customer on his, or her, guard.

Appropriate questions to ask in order to obtain an explanation of the reason for conducting a transaction bearing suspicious activity indicators will depend upon the circumstances of the financial activity observed. For example, if a customer wishes to make a large cash transaction then staff can ask the customer the reason for using cash on the grounds that the staff member may be able to offer advice on a more secure method to perform the transaction.

Another example is when a customer receives "structured" remittances from overseas. In such circumstances staff could question the customer on the reason for receiving numerous remittances within a short period of time on the grounds that one larger remittance would be quicker, cheaper for the sender to send, and less time consuming for the recipient to handle.

Persons engaged in legitimate business generally have no objection to, or hesitation in answering such questions. Persons involved in illegal activity are more likely to refuse to answer, give only a partial explanation or give an explanation which is unlikely to be true.

If a customer is unwilling, or refuses, to answer questions or gives replies which staff suspect are incorrect or untrue, this may be taken as a further indication of the suspicious nature of the financial activity.