Cash Placement

Description:

Involves the purchase of a product using cash, currency, or currency equivalents, or the transfer of cash, currency, or currency equivalents into a firm.

Appears in:
Addressed by:
  • Bank to Bank Transfers (Low Risk Jurisdictions): Payment can only be made via bank-to-bank transfers from countries with strong AML controls (typically low-risk jurisdictions).
  • Currency Defined in Agreement or Contract: A product or service requires entering into a legally binding agreement or contract between specified parties that defines the currency to be used.
  • Currency Reporting Requirements: Reporting of transactions exceeding EUR 10,000.
  • Documentary Evidence to Identity Parties and Details of Transaction: Agreement supported by underlying documentation (i.e., bills of lading, invoices, shipping documents, warehouse receipts, and warrants) that contains details of all parties to the transaction, currency, value, all countries involved, and the purpose of the transaction.
  • Documentary Evidence to Support Conditions of Agreement Met: Agreement supported by underlying documentation (bills of lading, invoices, shipping documents, warehouse receipts, and warrants) containing details of all parties involved in the transaction, currency, value, all countries involved, the purpose of the transaction, and allowing payment only when all conditions outlined in the terms of the instrument have been met.
  • Know Your Business (KYB): Includes taking steps to gain an understanding of a customer's business activities, including the nature of the business to be taken with a bank and the anticipated volume and value of the business.
  • Low Risk Multi-Banked Customer: The customer must establish more than one relationship with a firm or another official body (e.g., a regulator) in a low-risk jurisdiction.
  • No Transactions Prior to CDD or EDD: Entering into a transaction before completing CDD (Customer Due Diligence) or EDD (Enhanced Due Diligence), as appropriate, is not allowed.
  • Restricted to Regulated Firm: Restrictions on the types of customers (regulated Financial Institutions) to whom the product can be offered.