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FATF's New Terrorist Financing SORP: A Coded Message?

Chris Hamblin, Editor, Offshore Red, London, 11 July 2013

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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.

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