The AML policy is a basis for procedures and controls implemented by the Legal Compliance Department (LCD). AML procedures apply not only to banking and financial institutions that conduct direct remittances, but also to advisors that provide services that are well-informed about clients' activities. The European Commission has developed general guidelines with the list of transactions showing factors that explain how suspicious transactions can be identified. There is no threshold above which a transaction can be identified as suspicious. The situation must be analyzed on a case-by-case basis. Each factor, considered individually, may seem seamless, but when considered together, it can raise suspicions that the transaction is money laundering related. Among other things, the compliance department needs to know the customer about the nature of the transaction, the usual transfer numbers, the financial history and the background. When transactions do not appear to be in line with normal business practice, this may be a relevant factor in determining that the transaction appears suspicious. For this reason, banks have recently drawn attention to newly introduced customers and given them intensive support.

AML strategies
Examples of generally accepted indicators are: The customer transfers large amounts without payment details or receives large amounts without payment details. The customer presents confusing details about the transaction or knows very little about the purpose. The customer requests an express transfer and insists on making the transfer quickly, or he/she conducts transactions in different physical locations to avoid detection. The customer arbitrarily informs about large volume transactions, using unconventional accounting methods or confidential books. The customer does not respond to the invitation to a face-to-face meeting; normal attempts to background check a new or potential client are difficult. The client uses the PO box service instead of a real office or he/she seems to have recently established a number of new relationships with different financial institutions etc.

The applicable methodology may vary by organization, although the basic principles should be the same, e.g. B. Large cash transaction reporting, records, background checks, case management tracking system; Incident reporting database, company “hot file”, etc.

Sometimes companies face certain difficulties in the start-up phase. For example, to fill in the customer's questionnaire, who cannot show it to any business partner, since the company is new and no agreements have been made yet. Therefore, it is possible to update the customer questionnaire later to keep the bank informed of planned activities. At the time of opening an account, the bank must verify the source of income and the origin of funds.

If the bank determines that the transaction is suspicious or that the customer himself is suspicious, this must be reported to the competent authority.