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So, what sort of deviant activities

should you be aware of

when interacting with customers?

Let’s start with some examples of deviant behaviour:

The customer shows an unusual interest in our

Anti-Money Laundering and Counter-Terrorist Financing framework.

The customer provides documentation about

their employment or payment slips

that are false or appear to have been altered.

The customer is reluctant to provide us with

requested information about for example

the owner, control structure and who is beneficial owner.

The customer provides false information about

for example their contact details or their employment.

Most EnterCard customers have a transaction pattern,

which can be expected in relation to the products

and services we offer,

i.e. payments of outstanding balance occur once a month,

either in full or the minimum amount,

fund transfers or cash withdrawals may occur etc.

However, sometimes the transaction pattern

deviates and it can look something like these examples.

The customer frequently withdraws cash

and does not seem to be concerned with withdrawal fees.

Cash withdrawals are primarily made abroad.

Especially in non-EU high risk countries

such as Iraq, Iran, Afghanistan etc.

Unexpected repayment of an overdue credit

is made without any plausible explanation as to the source of funds.

The customer repays a loan unexpectedly fast

and shortly thereafter applies for a new loan.

The customer makes overpayments to the account

causing a positive balance

and then requests a refund payment for the excess.

Shortly after opening an account,

the customer empties the account,

leaving a negative account balance.

These examples of activities could of course have reasonable explanations,

but they could also be red flags for Money Laundering

or Terrorist Financing and require action from your side.

Whenever in doubt,

always ask your Manager how to proceed.