Annex 6: List of Areas That Pose Higher Risks
The following areas pose higher risks: • Products and Services. Some products and services offered by banks may pose a higher risk of money laundering or terrorist financing depending on the nature of the specific product or service offered by the bank. Some examples of these products and services are: • Electronic funds payment services: electronic cash, stored value cards, funds transfers, third-party payment processors, remittance activities, and automated teller machines • Electronic banking • Private banking • Trust and asset management services • Monetary instruments, official bank checks, cashier’s checks, money orders, and so forth • Foreign correspondent accounts: pouch activity and payable-through accounts1 • International trade finance and letters of credit • Lending activities, particularly loans secured by cash collateral and marketable securities • Nondeposit account services, nondeposit investment products, insurance, and safe deposit boxes • Services identified by regulators, governmental authorities, or other credible sources as being potentially high-risk for ML/FT • Customers and Entities. Any type of account is potentially vulnerable to money laundering or terrorist financing, but certain customers and entities may pose higher money laundering risks. Some examples of possible higher-risk accounts and activities are • Foreign financial institutions, including banks and foreign money services providers, exchange houses, money transmitters, and bureaux de change 223