FATF's New Terrorist Financing SORP: A Coded Message?
Chris Hamblin, Editor, Offshore Red, London, 11 July 2013
Some thoughts for private banks
Under the heading of “customer risk factors” it lists:
· business relationships conducted in unusual circumstances, perhaps when there is a significant and unexplained geographical distance between the financial institution and the customer;
· non-resident customers;
· legal persons or arrangements that are personal asset-holding vehicles;
· companies that have nominee shareholders or shares in bearer form;
· cash-intensive businesses; and
· unusual or excessively complex ownership structures.