Suspicious Transactions
Under the Proceeds of Crime Act and Regulations (2007), financial institutions are required to engage in transaction monitoring and reporting. Transaction monitoring imposes upon JN Money, its agents and sub agents, the requirement of knowing our customers to the extent that we will be able to detect when their activity might be suspicious, and thus warrant reporting to the authorities.
As alluded to above, the requirement to report potentially suspicious transactions forms part of the agent staff responsibility. Consequently, JN Money ensures that all agent staff are aware of red flags associated with suspicious activity through its Anti-money Laundering and Counter Financing of Terrorism and Proliferation Training. Agent staff should not, therefore, turn a blind eye to suspicious activity, but report any such activity to JN Money, using the channels provided.
Red Flags
The following are reminders of some red flags which can be used to inform your reporting of potential suspicious activity to JN Money:
| Examples of Red Flags | Scenarios |
| 1. Changes to customers pattern of activity | a. Unexplained increased frequency in sending or collecting remittances/multiple visits to agent within a day/week.
b. Unexplained increased value of remittances being sent or collected. |
| 2. Many to one scenario | c. Multiple senders to a single recipient
d. Recipient receiving remittances from multiple senders. e. Multiple senders across countries sending to a single or multiple recipients. f. Recipient receiving remittances from multiple countries. |
| 3. Lack of familiarity with sender | g. Recipient is unaware of pertinent information concerning their sender, such as senders correct name, address, telephone number, relationship.
h. Sender who appears unfamiliar with the intended recipient of the funds or the reason why the funds are being sent to the recipient. |
| 4. Validity of Identification | i. Anomalies associated with identification presented, such as name mismatch between what the name on the identification and the name on the transfer. |
| 5. High Risk Individuals | j. Recipient receiving funds from known Politically Exposed Persons (PEPs).
k. Senders associated with illegality/criminality, or who have been assessed as being part of a group of money mules. l. Elderly senders who are susceptible to being defrauded. |
While the above examples do not represent an exhaustive list, if you are ever in doubt concerning the suspicious nature of an activity, please contact JN Money Compliance Unit for further assistance and guidance.
How to Report
Agent staff can report potentially suspicious activity to the Nominated Officer at JN Money as follows:
- Using the eMoney platform, identify the Teller tab and scroll down to “submit suspicious transaction report” or identify the “report suspicious transaction” tab in the P2P Transfer Receipt window when paying a remittance.
- Completing an Internal Suspicious Transaction Report Form and sending it by email to the Money Laundering Reporting Officer (MLRO) of JNMS in your respective market.
Any of the above two modalities empowers agent staff to report suspicious activity to JN Money.
Remember, as agents of JN Money, you have an obligation to report suspicious activity. If in doubt, please contact the JN Money Compliance team for further support and guidance.
Fulfil your reporting obligation today!
