Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697628081559.pdf (Antigua and Barbuda)
MONEY LAUNDERING & THE FINANCING OF TERRORISM G UIDELINES FOR FINANCIAL INSTITUTIONS Update [ISSUED 21 March 2012] Director of the ONDCP and The Supervisory Authority under the Money Laundering (Prevention) Act 1996 O.N.D.C.P.
Headquarters Camp Blizard Antigua, West Indies Telephone: 562-3255, (268) 462-5934 Fax: (268) 460-8818 email: ondcp@candw.ag UPDATER PAGES MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendicies APPENDIX A — Typologies and Red Flags TYPES OF POTENTIALLY SUSPICIOUS ACTIVITIES AND TRANSACTIONS other negotiable and readily market- able money instruments; 1.
Money Laundering using cash transac- tions (a) unusually larger cash deposits made by an individual or company whose ostensible business activities would normally be generated by cheques and other instruments; (b) substantial increases in cash de- posits of any individual or business without apparent cause, especially if such deposits are subsequently transferred within a short period out of the account and/or to a destina- tion not normally associated with the customer; (c) customers who deposit cash by means of numerous credit slips so that the total of each deposit is un- remarkable, but the total of all the credits is signiﬁcant; (d) company accounts whose transac- tions, both deposits and withdrawals, are denominated by cash rather than the forms of debit and credit normally associated with commercial opera- tions (e.g.
cheques, Letters of Credit, Bills of Exchange, etc.
); (e) customers who constantly pay in or deposit cash to cover requests for money transfers, bankers drafts or (f) customers who seek to exchange large quantities of low denomination notes for those of higher denomina- tion; (g) frequent exchange of cash into other currencies; (h) branches that have a great deal more cash transactions than usual (Head Ofﬁce statistics detect aberrations in cash transactions); (i) customers whose deposits contain counterfeit notes or forged instru- ments; (j) customers transferring large sums of money to or from overseas locations with instruments for payment in cash; and (k) large cash deposits using night safe facilities, thereby avoiding direct con- tact with bank staff.
2.
Money Laundering using bank ac- counts (a) customers who wish to maintain a number of trustee or client accounts which do not appear consistent with the type of business, including trans- actions which involve nominees; (b) customers who have numerous ac- Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A counts and pay in amounts of cash to each of them in circumstances in which the total of credits would be a large amount; (c) any individual or company whose account shows virtually no normal personal banking or business related activities, but is used to receive or disburse large sums which have no obvious purpose or relationship to the account holder and/or his busi- ness (e.g.
a substantial increase in turnover on an account); (d) reluctance to provide normal infor- mation when opening an account, providing minimal or ﬁctitious infor- mation or, when applying to open an account, providing information that is difﬁcult or expensive for the institu- tion to verify; (e) customers who appear to have ac- counts with several institutions within the same locality, especially when the bank is aware of a regular consolida- tion process from such accounts prior to a request for onward transmission of the funds; (f) matching of payments out with cred- its paid in cash on the same or previ- ous day; (k) companies’ representatives avoiding contact with the branch; (l) substantial increases in deposits of cash or negotiable instruments by a professional ﬁrm or company, using client accounts or in-house company or trust accounts, especially if the deposits are promptly transferred be- tween other client, company and trust accounts; (m) customers who decline to provide information that in normal circum- stances would make the customer eligible for credit or for other banking services that would be regarded as valuable; (n) insufﬁcient use of normal banking facilities (e.g.
avoidance of high inter- est rate facilities for large balances); and (o) large number of individuals making payments into the same account without an adequate explanation.

(p) customers who request that account statements and other correspon- dence be kept at the ﬁnancial institu- tion for collection or from whom cor- respondence is returned “note known at this address” etc.

(g) paying in large third party cheques endorsed in favour of the customer; 3.
Money Laundering using investment related transactions (h) large cash withdrawals from a pre- viously dormant/inactive account, or from an account which has just received an unexpected large credit from abroad; (a) purchasing of securities to be held by the institution in safe custody, where this does not appear appropriate given the customer’s apparent stand- ing; (i) customers who together, and simul- (b) request by customers for invest- taneously, use separate tellers to conduct large cash transactions or foreign exchange transactions; (j) greater use of safe deposit facilities and increased activity by individuals; the use of sealed packets deposited and withdrawn; ment management or administration services (either foreign currency or securities) where the source of the funds is unclear or not consistent with the customer’s apparent stand- ing; (c) large or unusual settlements of secu- rities in cash form; and Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A (d) buying and selling of a security with no discernible purpose or in circum- stances which appear unusual.
4.

Money Laundering by offshore interna- tional activity identity of the ultimate beneﬁciary or counterpart is undisclosed, contrary to normal procedure for the type of business concerned.

6.
Money Laundering by secured and unsecured lending (a) customer introduced by an over- seas branch, afﬁliate or other bank based in countries where production of drugs or drug trafﬁcking may be prevalent; (b) use of letters of credit and other methods of trade ﬁnance to move money between countries where such trade is not consistent with the customer’s usual business; (c) building up of large balances, not consistent with the known turnover of the customer’s business, and sub- sequent transfer to account(s) held overseas; (d) unexplained electronic fund transfers by customers, foreign currency drafts or other negotiable instruments to be issued: (e) frequent requests for travelers cheques or foreign currency drafts or other negotiable instruments to be issued; and (f) frequent paying in of travelers cheques or foreign currency drafts particularly if originating from over- seas.
5.

Money Laundering involving ﬁnancial institution employees and agents (a) changes in employee characteristics, (e.g.

lavish lifestyles or avoiding tak- ing holidays); (b) changes in employee or agent per- formance, (e.g.
the salesman selling products for cash has remarkable or unexpected increase in perfor- mance); and (c) any dealing with an agent where the (a) customers who repay problem loans unexpectedly; (b) request to borrow against assets held by the institution or a third party, where the origin of the assets in not known or the assets are inconsistent with the customer’s standing; and (c) request by a customer for an institu- tion to provide or arrange ﬁnance where the source of the customer’s ﬁnancial contribution to the deal is unclear, particularly where property is involved.
(d) customers who unexpectedly repay in part or full a mortgage or other loan in a way inconsistent with their earning capacity or asset base.

7.

Sales and dealing staff A.

New Business Although long-standing customers may be laundering money through an invest- ment business it is more likely to be a new customer who may use one or more accounts for a short period only and may use false names and ﬁctitious companies.
Investment may be direct with a local institution or indirect via an intermedi- ary who “doesn’t ask too many awkward questions”, especially (but not only) in a jurisdiction where money laundering is not legislated against or where the rules are not rigorously enforced.
The following situations will usually give rise to the need for additional enquiries: (i) a personal client for whom veriﬁca- tion of identity proves unusually dif- ﬁcult and who is reluctant to provide Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A details; 1.
Dealing patterns (ii) a corporate/trust client where there are difﬁculties and delays in obtaining copies of the accounts or other docu- ments of incorporation: (iii) a client with no discernible reason for using the ﬁrm’s service, e.g.
clients with distant addresses who could ﬁnd the same services nearer their home base; clients whose requirements are not in the normal pattern of the ﬁrm’s business which could be more easily serviced elsewhere; and (iv) any transaction in which the counter- party to the transaction is unknown B.

Intermediaries There are many clearly legitimate rea- sons for a client’s use of an intermediary.
However, the use of intermediaries does introduce further parties into the transac- tion thus increasing opacity and, depend- ing on the designation of the account, preserving anonymity.

Likewise there are a number of legitimate reasons for deal- ing via intermediaries on a “numbered account” basis; however, this is also a useful tactic which may be used by the money launderer to delay, obscure or avoid detection.
Any apparently unnecessary use of an in- termediary in the transaction should give rise to further enquiry.

C. Dealing patterns & Abnormal trans- actions The aim of the money launderer is to introduce as many layers as possible.

This means that the money will pass through a number of sources and through a number of different persons or entities.

Long-standing and apparently legitimate customer accounts may be used to laun- der money innocently, as a favour, or due to the exercise of undue pressure.
(i) A large number of security transac- tions across a number of jurisdic- tions; (ii) Transactions not in keeping with the investor’s normal activity, the ﬁnan- cial markets in which the investor is active and the business which the investor operates; (iii) Buying and selling of a security with no discernible purpose or in circum- stances which appear unusual, e.g.
churning at the client’s request; (iv) Low grade securities purchased in an overseas jurisdiction, sold locally and high grade securities purchased with the proceeds; and (v) Bearer securities held outside a recognized custodial system.

2.
2.

Abnormal transactions (i) a number of transactions by the same counter-party in small amounts of the same security, each purchased for cash and then sold in one transaction, the proceeds being credited to an account different from the original account; (ii) any transaction in which the nature, size or frequency appears unusual, e.g.
early termination of packaged- products at a loss due to front end loading; early cancellation, especial- ly where cash had been tendered or the refund cheque is to a third party; (iii) transfer of investments to appar- ently unrelated third parties; (iv) transactions not in keeping with nor- mal practice in the market to which they relate, e.g.
with reference to market size and frequency, or at off- market prices; and Examples of unusual dealing patterns and abnormal transactions may be as follows: (v) other transactions linked to the transaction in question which could Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A be designed to disguise money and divert it into other forms or to other destinations or beneﬁciaries.

8.

Settlements A.
8.

Settlements A.

Payment name of persons other than the cli- ent.

C. Disposition As previously stated, the aim of money launderers is to take “dirty” cash and turn it into “clean” spendable money or to pay for further shipments of drugs, etc.
Many of those at the root of the underly- ing crime will be seeking to remove the money from the jurisdiction in which the cash has been received, with a view to its being received by those criminal elements for whom it is ultimately destined in a manner which cannot easily be traced.
The following situations should therefore give rise to further enquiries: (i) payment to a third party without any apparent connection with the inves- tor; (ii) settlement either by registration or delivery of securities to be made to an unveriﬁed third party; and (iii) abnormal settlement instructions, including payment to apparently un- connected parties.

9.

Company Formation and Management A.
Suspicious circumstances relating to the customer’s behaviour: (i) the purchase of companies which have no obvious commercial pur- pose; (ii) sales invoice totals exceeding known value of goods; (iii) customers who appear uninterested in legitimate tax avoidance schemes; (iv) the customer pays over the odds or sells at an undervaluation; (v) the customer makes unusually large cash payments in relation to busi- ness activities which would normally be paid by cheques, banker’s drafts Money launderers will often have sub- stantial amounts of cash to dispose of and will use a variety of sources.
Cash settlement through an independent ﬁnan- cial adviser or broker may not in itself be suspicious; however, large or unusual settlements of securities deals in cash and settlements in cash to a large securi- ties house will usually provide cause for further enquiry.
Examples of unusual pay- ment settlement may be as follows: (i) a number of transactions by the same counter-party in small amounts of the same security, each purchased for cash and then sold in one trans- action; (ii) large transaction settlement by cash; and (iii) payment by way of cheque or money order transfer where there is a varia- tion between the account holder/sig- natory and the customer.

B.
B.

Registration and delivery Settlement by registration of securities in the name of an unveriﬁed third party should always prompt further enquiry.

Bearer securities, held outside a recog- nized custodial system, are extremely portable and anonymous instruments which may serve the purpose of the money launderer well.
Their presenta- tion in settlement or as collateral should therefore always prompt further enquiry as should the following: (i) settlement to be made by way of bearer securities from outside a rec- ognized clearing system; and (ii) allotment letters for new issues in the Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A etc; (vi) customers transferring large sums of money to or from overseas locations with instructions for payment in cash; (vii) customers who have numerous bank accounts and pay amounts of cash into all those accounts which, if taken in total, amount to a large overall sum; and (viii) paying into bank accounts large third party cheques endorsed in favour of the customers.
B.Potentially suspicious secrecy might involve: (i) excessive or unnecessary use of nominees; (ii) unnecessary granting of power of at- torney; (v) frequent changes in shareholders and directors; (vi) unexplained transfers of signiﬁcant sums through several bank accounts; and (vii) use of bank accounts in several cur- rencies without reason.

10.
10.

Casinos and internet gaming business (a) customer who request that payouts be sent to third parties, particularly, in jursidictions other than their juridic- tion of domicile; (b) customers who deposit signiﬁcant sums into their player accounts and then withdraw the money without having undertaken much gaming activity; (c) customers who engage in structuring; (iii) performing “execution only” transac- (d) where a customer is paid on a losing tions; wager.
(iv) using a client account rather than Notes: paying for things directly; (v) use of mailing address; (vi) unwillingness to disclose the source of funds; and (vii) unwillingness to disclose identity of ultimate beneﬁcial owners.

C. Suspicious circumstances in groups of companies: (i) subsidiaries which have no apparent purpose; (ii) companies which continuously make substantial losses; (iii) complex group structures without cause; (iv) uneconomic group structures for tax purposes; 1.
None of the above factors on their own necessarily mean that a customer or other person is involved in money laun- dering or terrorist ﬁnancing.

However, it may be that a combination of some of these factors could raise suspicions.

2.

What does or does not give rise to a suspicion will depend on the particular circumstances.
Developing an Early-Warning System for Suspicious NPOs1 Identifying red ﬂags Financial institutions are required by section 34(4) of the Prevention of Terrorism Act 2005 to report suspicious transactions relating to the ﬁnancing of terrorism2.

Terrorism ﬁnanc- ing tends to manifest itself either as money laundering or in other more subtle ﬁnancial activities.
This needs to be kept in mind when monitoring the accounts and transactions Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A of Non-Proﬁt Organizations (NPOs)3, which are legal entities or organizations that pri- marily engage in raising or disbursing funds for purposes such as charitable, religious, cultural, educational, social or fraternal pur- poses, or for the carrying out of other types of “good works”.
It is therefore important for ﬁnancial institutions dealing with NPO cus- tomers to be able to spot red ﬂags or indi- cators that suggest the possibility or poten- tial for transactions to be terrorism related.

Red ﬂags are particular behaviours and atypical situations that present themselves in transac- tions of customers and users of ﬁnancial insti- tutions that could be linked to illegal activities.
Red ﬂags related to Non-Proﬁt Organiza- tions and their activities include the following: (1) NPOs whose corporate purpose do not pertain to the place in which they carry out their activities; (2) NPOs that despite being tax exempt do not take advantage of that beneﬁt; (3) The transfer of money between local and foreign NPOs that because of the quantity, destination, or corporate purpose do not ﬁt the characteristics of the NPO from which it came; (4) NPOs that suddenly show a signiﬁ- cant increase in volume or amount of incomes; (5) NPOs that after remaining ﬁnancially inactive for some time make trans- actions for sums signiﬁcantly higher than usual; (6) NPOs that keep their ﬁnancial prod- ucts funded for very long periods of time; (7) Financial products under the name of the NPO that present a high volume of cash transactions; (8) NPOs that despite developing proj- ects for high sums of money do not have either the employees or the capacity to execute those projects; (9) NPOs that open ﬁnancial products with hardly veriﬁable personal and/or commercial references, or whose partners or legal representatives are never in the country; (10) NPOs which use a name that sug- gest a relationship with another rec- ognized NPO or is similar to another NPO in order to deceive potential donors or clients; (11) NPOs that often make changes in their shareholders, legal representa- tives, and/or administrators; (12) NPO employees or executives who claim to work for the organization but do not have legal permits to work in that country; (13) NPOs that are lawfully constituted but manage their ﬁnancial resources through the personal bank accounts of their executives or employees, thus avoiding opening ﬁnancial prod- ucts on behalf of the NPO as such.
in- The compliance ofﬁcers of ﬁnancial thorough should develop a stitutions familiarity with red ﬂags and these communicate them during training and or- dinary interaction to other members of staff.
Footnotes 1 2 3 Based on OAS recommendations S.34(4) of the PTA requires a ﬁnancial insti- tution to report every transaction, attempted transaction or proposed transaction where there are reasonable grounds to suspect the transaction, attempted transaction or pro- posed transaction is related to terrorism, is conducted on behalf of a terrorist or terrorist organization or on behalf of a ﬁnancier of ter- rorism.

Some NPOs are referred to as Friendly Soci- eties.
Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES APPENDIX B — Summary of AML/CFT Laws Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix B Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES APPENDIX C — Financial Institutions under the MLPA Financial activities subject to the require- ments of the Money Laundering (Preven- tion) Act are set out in the First Schedule to the Act and are as follows: 13.
Building societies; 14.

Trust business; 15 Insurance business; 1.

2.

“Banking business” and “ ﬁnancial business” as deﬁned in the Bank- ing Act and the Financial Institutions (Non-Banking) Act; “International offshore Banking busi- ness” as deﬁned in the International Business Corporation Act; 3.

Venture risk capital; 4.

Money transmission services; 5.

Issuing and administering means of payments (e.g.

credit cards, travel- lers’ cheques and bankers’ drafts); 16.
Dealers in precious metals, art and jewellery; 17.

Casionos; 18.

Internet gambling 19.

Sports betting 20.

Car Dealerships; 21.

Travel agents; 22.

Dealers in high value and luxury goods; 6.

Guarantees and commitments; 23.

Company service providers; 7.

Trading for own account or for ac- 24.

Attorneys-at-law (who conduct ﬁnan- count of customers in:— cial activity as a business); 25.

Notaries (who conduct ﬁnancial activ- ity as a business(; 26.
Accountants (who conduct ﬁnancial activity as a business).

(a) money market instruments (e.g., cheques, bills, certiﬁcates of depos- its, commercial paper, etc.

); (b) foreign exchange; (c) ﬁnancial and commodity-based derivative instruments (e.g., futures, options, interest rate and foreign exchange instruments etc.

); (d) transferable or negotiable instru- ments; 8.

Money broking; 9.

Money lending and pawning; 10.

Money exchange (e.g., casa de cam- bio); 11.
Real property business; 12. Credit unions; Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES APPENDIX D — Forms Forms relevant to complaince with the re- quirements of the MLPA and the PTA are the following: REPORTING FORMS Form 1 — Suspicious Activity Report Form 1A — Suspicious Activity Report (Gaming) Form 1C — Signiﬁcant Payment Re- port (Gaming) Form 3 — Terrorist Property Report NOTICE FORMS Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix D Suspicious Activity Report COMPLETE ENTIRE REPORT (see Instructions) Please complete this form in black ink and print in CAPITAL LETTERS Mark appropriate answer boxes with a check (√) Instructions on how to prepare a suspicious activity or transaction report using this form are enclosed with the form or can be obtained from the ONDCP.
This Report is a confidential document and must be treated as such.

CONFIDENTIAL Complete ALL items on this form, as soon as possible AFTER the transaction or attempted transaction or activity that is the subject of this report.

Items that are not applicable should be left blank.
Reporting of suspicious transactions by financial institutions is required by law under Sec- tion 13 of the Money Laundering (Prevention) Act 1996 as amended (“MLPA”) and regulation 6(1) of the Money Laundering (Prevention) Regulations 2007.

A list of all financial institutions required to file suspicious transaction reports (“STR”) is found in the First Schedule to the MLPA.
Tipping off: Financial institutions (including employees, staff, directors, owners or other authorized representatives) shall not notify any person that this SAR has been filed and information relating thereto furnished to the Supervisory Authority.

Criminal offence is com- mitted contrary to section 13(5) of the MLPA for failure to comply with this obligation.

Send the completed form to: THE SUPERVISORY AUTHORITY ONDCP Headquarters P.O.
Box W 827, Camp Blizard, Antigua Tel: (268) 562-3255 email: supervisoryauthority@ondcp.gov.ag Privacy Statement The provisions of Section 13 of the MLPA and Regulations 6 of the MLPR are designed to help detect money laundering and uncover transactions invovling the proceeds of crime.

Information reported to the Supervisory Authority at the ONDCP is kept confidential.
However, the Supervisory Authority is legally authorised to share the information with another law enforcement authority where the disclosure is essential to the detection, investigation or prosecution of an offence.

Financial institutions, are protected by Section 13(4)of the MLPA from criminal, civil or administrative liability for complying with the legal requirement to file reports of transactions that constitute or could be related to money laundering.
Penalties exist for failure to lodge or supply full and correct information as required.

For assistance please call the Senior Financial Intelligence Officer of the ONDCP at (268) 562-3255 Timing of Report Reporting is required by Section 13(2) of the MLPA to be done promptly.

Reports of suspicious transactions or activities must be made as soon as practicable, but no later than 30 days after the suspicious activity/transaction is discovered.
Please note the time when the suspicious transaction/activity occurred, the time when you start to fill out this form and the time when you complete this form.

You may be asked about how long it took to prepare and file this report.

A SAR must be in writing.

Contact with law enforcement authorities does not eliminate or satisfy the section 13(2) requirement of the MLPA to make an SAR.

1 Check the box if this report is made to correct or update a prior report.
Where a correction is being filed, the entire form must be completed again and changes indicated in the appropriate item.
PART A - IDENTITY OF SUBJECT(S) CONDUCTING THE SUSPICIOUS ACTIVITY OR TRANSACTION 2 3 Subject information unavailable Multiple subjects involved FORM 1 SUBJECT INFORMATION 4 Name of individual or entity (a) Surname or name of entity: ....................................................... ......................................................................................................... (b) First name:................................................................................. (c) Middle name:.............................................................................. (d) alias (if any):............................................................................... (e) trading as:................................................................................... 5 Address (a) Street.................................................................................. (b) City:....................................................................................................... (c) State/province:...................................................................................... (d) Postcode:............................................................ (e) Country:................................................................................................. 6 Date of birth (dd/mm/yyyy).................................................. 7 Country of registration ......................................................................................................... 8 Occupation/Type of business ......................................................................................................... 9 (a) Telephone number (home):..................................................... (b) Telephone number (business):................................................. 10 (a) Forms of identity veriﬁcation (i) passport - no.
............................................................ (ii) driver’s licence - no.

................................................ (iii) voter registration card - no.

..................................... (iv) identity card - no.

..................................................... (v) certiﬁcate of incorporation - no.
............................... (vi) other:........................................................................ (b) Authority that issued document(s):............................. .............................................................................................. 11 Subject’s relationship to the reporting ﬁnancial institution (a) Customer (b) Accountant (c) Agent (d) Appraiser (e) Attorney (f) Borrower (g) Broker (h) Director (i) Employee (j) Ofﬁcer (k) Shareholder (l) Other:............................. 12 Is the subject working with or for the institution?
(a) Yes No Subject is (b) still employed (c) suspended (d) terminated (e) resigned 13 Date of suspension, termination or resignation: .....................
Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix D PART B - DETAILS OF THE TRANSACTION OR ACTIVITY 14 Type of ﬁnancial services involved in suspicious trans- action..................................................................................... 15 Date or date range of suspicious transaction or activity From............................... to .............................................. 16 E.C.
Dollar amount of transaction(s) E C D $ , , .

0 0 17 If foreign currency is involved in the transaction(s) specify the currency and the amount Currency Amount , , , , , , , , .

.

.

.
0 0 0 0 0 0 0 0 18 Type and quantity of instrument(s) involved (1) ........................................................................................ (2) ........................................................................................ (3) ........................................................................................ 19 Transaction number(s)..................................................... PART C - SUMMARY CHARACTERIZATION OF SUSPICIOUS ACTIVITY 22 Category of Suspicious Activity.
Check the box(es) which best identify the suspicious activity: (A numbered list of typologies is attached to the end of the instructions for preparing this form.)
(a) Structuring (or layering) (b) Money laundering (c) Cheque Fraud (d) Computer Intrusion (e) Counterfeit Cheque (f) Counterfeit Instrument (g) Credit Card Fraud (h) Debit Card Fraud (i) Embezzlement (j) False invoicing (k) Identity Theft (l) Investment Fraud (m) Mysterious Disapperance (n) Refusal/failure to complete CDD requirements (o) Refusal/failure to update CDD information (p) Terrorist Financing (q) Wire Transfer Fraud (r) The suspicious activity resembles typology No.
............. (s) Other:........................................................................ 20 Accounts affected: 23 Character of suspicious activity (1) Account number:........................................................ (2) Account number::........................................................ (3) Account number::........................................................ (4) Account number::........................................................ 21 If account closed, date closed (1) date ....................... (2) date ....................... (3) date ....................... (4) date ....................... (a) unusual transaction (b) complex transaction (c) large transaction (d) unusual pattern of transactions with no apparent economic purpose (e) insigniﬁcant but periodic transactions with no appar- ent economic purpose (f) unusual use of monetary instrument (g) other:........................................................................
Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix D PART D - DESCRIPTION AND EXPLANATION OF SUSPICIOUS TRANSACTION /ACTIVITY 24 Give the reasons why you consider the transaction or activity reported in Part B to be suspicious.

(If there is insufﬁcient space, continue the narrative on a separate sheet of paper.)

This section of the report is critical.


The care with which it is written may make the difference in whether the described conduct and its possible criminal nature are clearly understood.

Provide below a chronological and complete account of the activity, including what is unusual, irregular or suspicious about the transaction, using the following checklist as you prepare your account.

a.

Describe the conduct that raised suspicion, why it was suspicious and the date(s) discovered.

b.
b.

Explain whether the transaction(s) was completed or only attempted.

c. Describe supporting documentation (e.g., transaction records, new account information, correspondence.)

Retain the originals.

d. Explain who beneﬁted, ﬁnancially or otherwise, from the transaction, how much, and how.

e. Retain any admission or explanation of the transaction provided by the suspect or any other person and indicate to whom and when it was given.
f. Retain any evidence of an attempt to deceive the ﬁnancial institution as to the actual nature of the transaction or amount of the transaction the subject sought to carry out.

g. Indicate where a possible violation of law took place, if possible.

h. Indicate whether the activity is an isolated incident or relates to an- other transaction(s).

Note whether this is an updated report and if so, provide the date of the original SAR regarding this activity.

i.
i.

Indicate whether currency and/or monetary instruments were in- volved.

If so, provide the amount and/or description of the instrument (for example, bank draft, letter of credit, money order, stocks, bonds, traveler’s cheques, wire transfers sent or received, cash, etc.)

and country of origin.

j.

Describe any funds transfers, including any in or out identiﬁcation numbers, parties involved, dates, amounts, and ﬁnancial institutions involved.
k. Indicate for a foreign national any available information on subject’s passport(s), and/or identiﬁcation card(s).

Include date, country, city of issue, issuing authority, and nationality.

l. Describe subject(s) position if employed by or afﬁliated with the ﬁnancial institution.

m. Indicate the type of institution ﬁling this report, if this is not clear.
n. Indicate if a law enforcement agency other than the ONDCP has been contacted, list the name of the agency and the name of any person contacted, their title, their telephone number, and when they were contacted.

o.

Recommend any further action that you consider might assist law enforcement authorities p. Indicate whether any information has been excluded from this report; if so, state reasons.

q.

Indicate any account number(s) that may be involved or affected.
r. If correcting or amending a prior report, complete the form in its entirety and note the items that contain the changes .

Take Note: SARs are conﬁdential and must be handled accordingly.

25 Is additional information attached to this report?

No Yes If yes, please specify:.....................................................................................................................................
Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix D PART E - DETAILS OF REPORTING FINANCIAL INSTITUTION PART F - STATEMENT OF REPORTING FINANCIAL INSTITUTION 26 Type of ﬁnancial institution reporting ............................................................................................ 32 This statement is made by the ﬁnancial institution named in Part E pursuant to the requirement of Section 13(2) of the MLPA to report suspicious transactions and is based on the information provided in Part D. 27 Name of ﬁnancial institution .............................................................................................. 28 Address of ﬁnancial institution I declare the information contained in this report to be correct to the best of my knowledge, information and belief.
Street......................................................................................
Date report prepared (dd/mm/yyyy): City:.............................................................................................................. State/province:............................................................................................ SIGN HERE Signature of Compliance Ofﬁcer or authorised person Postcode:............................................................ Country:....................................................................................................... email:......................................................................... 29 Location of branch where transaction or activity or the attempt took place (if different from item 26 above) Street...................................................................................... City:.............................................................................................................. State/province:............................................................................................ Postcode:............................................................ Country:.......................................................................................................
Check box if the suspicious activity took place in 30 more than one branch or location and indicate this informa- tion in Part D. 31 Details of Compliance Ofﬁcer or authorised person who can be contacted for assistance in this matter Name....................................................................................
Position:................................................................................................... Ofﬁce Address:............................................................................................ Telephone:............................................................ Fax:....................................................................... email:......................................................................... Report number Case Ofﬁcer OFFICIAL USE ONLY Comments Supervisory Authority, Antigua and Barbuda September, 2011 Revised 18 April 2008 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix D Suspicious Activity Report (Internet Gaming) Form Revised — 31 October 2008 To: The Supervisory Authority ONDCP Headquarters Camp Blizard, Antigua COMPLETE ENTIRE REPORT (see Instructions) Please complete this form in black ink and print in CAPITAL LETTERS Mark appropriate answer boxes with a check (√) Instructions on how to prepare a suspicious activity report using this form are enclosed with the form or can be obtained from the ONDCP.
CONFIDENTIAL This Report is a confidential document and must be treated accordingly.

Internet Gambling Companies are listed as financial institutions in the First Schedule to the Money Laundering (Prevention) Act 1996 (as amended) (“MLPA”).
Reporting to the Supervis- roy Authority of fraudulent or suspicious transactions which may involve money laundering or an activity similar to money laundering is required of of financial institutions, including internet gambling companies by Section 13 of the MLPA and Regulation 223 of the Interactive Gaming and Interactive Wagering Regulations 2007 ( IGIWR).

Such reports must be made using this form (either Form 1A or its electronic version Form 1A-e).
Tipping off: Financial institutions (including employees, staff, directors, owners or other authorized representatives) shall not notify any person that this SAR has been filed and information relating thereto requested by or furnished to the Supervisory Authority.

Criminal offence is committed contrary to section 13(5) of the MLPA for failure to comply with this obligation.

Submit the completed form to: THE SUPERVISORY AUTHORITY ONDCP Headquarters P.O.
Box W 827, Camp Blizard, Antigua Tel: (268) 562-3255 Help: (268) 562-3255 email: ondcp@ondcp.gov.ag Fax: (268) 460-8818 Privacy Statement The provisions of Section 13 of the MLPA and Regulations 223 of the IGIWR are designed to help detect money laundering and uncover the proceeds of crime.

Information reported to the Supervisory Authority at the ONDCP is kept confidential.
However, the Supervisory Authority is legally authorised to share the information with another law enforcement authority where the disclosure is essential to the detection, investigation or prosecution of an offence.
As financial institutions, Gaming Companies and their employees are required by Regulation 223 to file suspicious activity reports and authorised by Regulation 158(c) of the IGIWR to disclose information required to enforce the Regulations, and are protected by Section 13(4)of the MLPA from criminal, civil or administrative liability for complying with the legal requirement to file reports of transactions that constitute or could be related to money laundering.
Penalties exist for failure to supply full and correct information as required.

For assistance please call the Manager of the Financial Intelligence Unit of the ONDCP at (268) 562-3255 Important Note Reporting is required to be done promptly.

Under Regulation 223 of the IGIWR reports of suspicious transactions or activities that may involve money laundering must be made within 24 hours or as soon as practicable after the activity being reported.
Please note the time when the suspicious transaction/activity or payment occurred and the time when you start to complete this form.

You may be asked how long you took to complete it.
FORM 1A SUBJECT INFORMATION 4 (a) Name of individual or entity: Surname: .................................................................. First name: ............................................................... Middle name: ............................................................. (b) alias (if any): .............................................................. (c) trading as: ................................................................ 5 Address (cannot be a P.O.
Box) Street: .......................................................................... City: ............................................................................ State/province: ............................................................... Postcode: ..................................................................... Country: ....................................................................... 6 Date of birth: ........................... (dd/mm/yyyy) 7 (a) Forms of identity veriﬁcation (i) passport - no.
: (ii) driver’s licence - no.

: (iii) voter registration card - no.

: (iv) identity card - no.

: (v) certiﬁcate of incorporation - no.
: (vi) other: ....................................................... ............................................ .................................. ................................................ ........................... .................................................................. .......................... ............................................................................. (b) Authority that issued document(s): 8 Subject’s relationship to the reporting ﬁnancial institution (a) Customer/Player (b) Accountant (c) Agent (d) Appraiser (e) Attorney (f) Director (g) Employee (h) Ofﬁcer (i) Shareholder (j) Other: ........................... 9 Player account number (if any) ......................................... 10 Is the subject working with or for the reporting institution?
1 Check the box if this report is made to correct or update a prior report.
Where a correction is being filed, the entire form must be completed again and changes indicated in Part D. (a) Yes No The Subject is PART A - IDENTITY OF SUBJECT(S) CONDUCTING THE SUSPICIOUS ACTIVITY OR TRANSACTION Subject information unavailable Multiple subjects involved 2 3 (b) still employed (c) suspended (d) terminated (e) resigned 11 Date of suspension, termination or resignation: .................... (dd/mm/yyyy) Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix D PART C - SUMMARY CHARACTERIZATION OF SUSPICIOUS ACTIVITY 21 Category of Suspicious Activity.
Check the box(es) which best identiﬁes the suspicious activity that con- stitutes or could be related to money laundering: (If needed, a numbered list of typologies is attached to the end of the instructions for preparing this form.)
(a) Structuring (b) Money laundering (c) Cheque Fraud (d) Computer Intrusion (e) Counterfeit Cheque (f) Counterfeit Instrument (g) Credit Card Fraud (h) Debit Card Fraud (i) Embezzlement (j) Identity Theft (k) Mysterious Disapperance (l) Refusal/failure to complete CDD requirements (m) Refusal/failure to update CDD information (n) Terrorist Financing (o) Wire Transfer Fraud (p) The suspicious activity resembles typolog(ies) No.
............ (q) Other: ................................................................. 22 Character of suspicious activity (a) unusual transaction (b) complex transaction (c) large transaction (d) unusual pattern of transactions with no appar- ent economic purpose (e) insigniﬁcant but periodic transactions with no apparent economic purpose (f) unusual use of monetary instrument (g) other: ........................................................................ PART B - DETAILS OF THE TRANSACTION OR ACTIVITY 12 Date or date range of suspicious transaction(s) or activ- ity From ........................... (dd/mm/yyyy) to ........................... (dd/mm/yyyy) 13a Type of gaming/wagering activity (game, sports event etc.)
invovled: and/or ................................................................. 13b Type of transaction involved (eg.

deposit, wager, pay- ment etc.

): ..................................................................... 14 URL of website involved ................................................................................. 15 Currency and the amount involved in transaction(s).

If more than one currency is involved list each currency and its amount.
(For conversion rates check ) Currency U S D Amount , , , , , , .

.

.

0 0 0 0 0 0 16 Total value of transaction(s) in U.S.

Dollars 16 Total value of transaction(s) in U.S.

Dollars U S D , , .
0 0 17 Type and quantity of instrument(s) involved Type Quantity (1) (2) (3) ........................................ ........................................ ........................................ ........................... ........................... ........................... 18 Transaction number(s) ................................................................................. ................................................................................. 19 Accounts affected (1) Account number: (2) Account number: (3) Account number: .................................................... .................................................... .................................................... 20 If account(s) were closed, date closed (1) date (2) date (3) date (4) date ........................... ........................... ........................... ...........................
Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix D PART D - DESCRIPTION AND EXPLANATION OF SUSPICIOUS TRANSACTION /ACTIVITY 23* Give the reasons why you consider the transaction(s) or activity reported in Parts B and C to be suspicious.

(If there is insufﬁcient space, continue the narrative on a separate sheet of paper.)

This section of the report is critical.


The care with which it is written may make the difference in whether the described conduct and its possible criminal nature are clearly understood.

Provide below a chronological and complete account of the activity, including what is unusual, irregular or suspicious about the transaction, using the following checklist as you prepare your account.

a.

Describe the conduct that raised suspicion, why it was suspicious and the date(s) it occurred.

b.
b.

Indicate any account number(s) that may be involved or affected.

c. Explain whether the transaction(s) was completed or only attempted.

d. Describe supporting documentation (e.g., transaction records, new account information, correspondence.)

Retain the originals.

e. Explain who beneﬁted, ﬁnancially or otherwise, from the transaction, how much, and how.

f. Retain any admission or explanation of the transaction provided by the suspect or any other person and indicate to whom and when it was given.
g. Retain any evidence of an attempt to deceive the ﬁnancial institution as to the actual nature of the transaction or amount of the transaction the subject sought to carry out.

h. Indicate where a possible violation of law took place, if possible.

i.

Indicate whether the activity is an isolated incident or relates to another transaction(s).

j.

Indicate whether currency and/or monetary instruments were in- volved.
If so, provide the amount and/or description of the instrument (for example, bank draft, money order, wire transfer sent or received, cash, etc.)

and country of origin.

k. Describe any funds transfers, including any in or out identiﬁcation numbers, parties involved, dates, amounts, and ﬁnancial institutions involved.

l. Indicate for a foreign national any available information on subject’s passport(s), and/or identiﬁcation documents(s).
Include date, country, and city of issue, issuing authority, and nationality.

m. Describe subject(s) position if employed by or afﬁliated with reporting the ﬁnancial institution.

n. Indicate if a law enforcement agency other than the ONDCP has been contacted, list the name of the agency and the name of any person contacted, their title, their telephone number, and when they were contacted.

o.
o.

Recommend any further action that you consider might assist law enforcement authorities p. Indicate whether any information has been excluded from this report; if so, state reasons.

q.

If correcting or amending a prior report, complete the form in its entirety and point out the items that contain the changes .

r. If updating a prior report provide the date of the original SAR regard- ing the activity.

Take Note: SARs are conﬁdential and must be handled accordingly.
24 Is additional information attached to this report?

No .............................................................................................................. ...............................................................................................................................................................................
If yes, please specify: Yes Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix D PART E - DETAILS OF REPORTING COMPANY 25 Name of Licence Holder (company ﬁling report) ................................................................................. 26 Address of Licence Holder 29 Details of Money Laundering Compliance Ofﬁcer or authorised person submitting the report Name: ..........................................................................
Position: ....................................................................... Street: ......................................................................... Ofﬁce Address: City: ............................................................................ Street: ......................................................................... State/province: ............................................................... City: ........................................................................... Postcode: ............................................................... State/province: .............................................................. Country: .................................................................. 27 Address of ofﬁce issuing the report Postcode: ................................................ Country: ....................................................................... Street: ......................................................................... Telephone: ............................................ City: ............................................................................ Fax: ..................................................... State/province: ............................................................... email: ...................................... Postcode: ............................................................... Country: .................................................................. 28 Physical address of ofﬁce/facility from which the trans- action or activity was processed or detected (if different ......................................................................... from 27 above) Street: ......................................................................... City: ............................................................................ State/province: ........................................................ Postcode: ............................................................... Country: .................................................................. PART F- STATEMENT OF THE LICENCE HOLDER 30 This report is made by or on behalf of the Licence Hold- er named in 23 above pursuant to the requirement to report fraudulent or suspicious transactions that may involve money laundering under Regulation 223 of the IGIWR and Section 13 of the MLPA, and is based on the grounds set out in Part D. I declare the information contained in this report to be correct to the best of my knowledge, information and belief.
Date ........................... (dd/mm/yyyy) SIGN HERE ....................................................................... Signature of Compliance Ofﬁcer or authorised person Report number Case Ofﬁcer OFFICIAL USE ONLY Comments Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A Significant Payment Report (over US$25,000) Internet Gaming To: The Supervisory Authority ONDCP Headquarters Camp Blizard, Antigua Form revised 31 October 2008 COMPLETE ENTIRE REPORT (see Instructions) FORM 1C 3 Player account address (cannot be a P.O.
Box only) Street: ......................................................................... City: ............................................................................ State/province: ............................................................... Postcode: ..................................................................... Country: .......................................................................
Please complete this form in black ink and print in CAPITAL LETTERS Mark appropriate answer boxes with a check (√) 4 Date of birth Instructions on how to prepare a significant payment report using this form are enclosed with the form or can be obtained from the ONDCP.

This Report is a confidential document and must be treated accordingly.
CONFIDENTIAL Reporting to the Supervisory Authority by internet gambling companies of payments made to players from the player’s account exceeding the threshold of US$25,000 is required by regu- lation 148(d) of the Interactive Gaming and Interactive Wagering Regulations 2007 (IGIWR).

Such reports must be made using this form (Form 1C or its electronic version Form 1C-e).

For purposes of this form, such reports may be referred to as “significant payment reports”.
Complete and submit this form within 48 hours of the payment being made.

If there is reason to suspect that the payment being reported may involve money laundering activity, then in addition, a separate suspicious activity report must be made on the appropri- ate form (Form 1A).

Submit the completed form to: THE SUPERVISORY AUTHORITY ONDCP Headquarters P.O.
Box W 827, Camp Blizard, Antigua Tel: (268) 562-3255 Help: (268) 562-3261 email: supervisoryauthority@ondcp.gov.ag Fax: (268) 460-8818 Currency U S D Privacy Statement The provisions of Regulation 148(d) of the IGIWR are designed to help detect money laundering activity and uncover the proceeds of crime.

Information reported to the Supervisory Authority at the ONDCP is kept confidential.
However, the Supervisory Authority is legally authorised to share the information with another law enforcement authority where the disclosure is essential to the detection, investigation or prosecution of an offence.

As financial institutions, Gaming Companies and their employees are author- ised by Regulation 158(c) of the IGIWR to disclose information required to enforce the Regulations.

Penalties exist for failure to comply with the regulatory requirement.
For assistance please call the Manager of the Financial Intelligence Unit of the ONDCP at (268) 562- 3255 ............................................... (dd/mm/yyyy) PART B - DETAILS OF THE PAYMENT 5 Name of gaming activity that resulted in payout ....................................................................................... 6 Date of payment ............................................... (dd/mm/yyyy) 7 Method of payment (eg.
wire to credit card account, cheque to Player’s account address) ....................................................................................... 8 Amount paid out by reporting licence holder: If more than one currency is involved in the transaction(s) list each currency and its amount , , , , Amount , , , , .

.

.

.

0 0 0 0 0 0 0 0 9 Total value of transaction(s) in U.S.

Dollars U S D , , .

0 0 PART C - COMMENTS Important Note Reporting is required to be done promptly.
Under Regulation 148(d) reports of pay- ments exceeding US$25,000 must be made within 48 hours of the payment.
Please note the time when the payment occurred and the time when you complete this 10 Comment on anything noteworthy or unusual about the nature and circumstances concerning how the money was won or ob- tained or the payout made as reported in Part B PART A - IDENTITY OF PERSON TO WHOM PAYMENT WAS MADE 1 Player account number ...................................................... 2 (a) Name of Player Surname: .................................................................. First name: ............................................................... Middle name: ............................................................. (b) alias (if any): ..............................................................
Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A PART D - DETAILS OF REPORTING GAMING COMPANY PART E - STATEMENT OF REPORTING FINANCIAL INSTITUTION 11 Name of Licence Holder (company making report) ................................................................................. 12 Address of Licence Holder Street: ......................................................................... 15 This report is made by or on behalf of the Licence Holder named in item 11 above pursuant to the requirement to report all payments to a player from the player’s account exceeding U.S.$25,000 under Regulation 148(d) of the IGIWR.
I declare the information contained in this report to be cor- rect to the best of my knowledge, information and belief.

City: ............................................................................
Date (dd/mm/yyyy) ............................................... State/province: ............................................................... Postcode: ..................................................................... SIGN HERE ....................................................................... Signature of Compliance Ofﬁcer or authorised person Country: ....................................................................... 13 Physical address of ofﬁce/facility from which the payout was made or the transaction or activity processed (if different from 12 above) Street: ......................................................................... City: ............................................................................ State/province: ............................................................... Postcode: ..................................................................... Country: ....................................................................... 14 Details of Compliance Ofﬁcer or authorised person submitting the report Name: .........................................................................
Position: ...................................................................... Ofﬁce Address: Street: ......................................................................... City: ............................................................................ State/province: ............................................................... Postcode: ..................................................................... Country: ....................................................................... Telephone: .................................................................... Fax: .................................................................... email: .................................................................... Report number Case Ofﬁcer OFFICIAL USE ONLY Comments Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A FORM 3 Terrorist Property Report (Section 34 of the Prevention of Terrorism Act 2005) Submit the completed form to the Director, ONDCP Headquarters, P.O.
Box W827, Camp Blizard, Antigua If you are a ﬁnancial institution or person that has property in your possession or control that you believe is owned or con- trolled by or on behalf of a designated terrorist or terrorist organisation or are making a quarterly statutory report on whether or not you possess or control such property, you should use this form to make a report of the property to the Director of the ONDCP.
A designated terrorist or terrorist organisation is one that has been so designated by publication of the entitiy’s name and details in the Gazette by the Attorney General pursuant to Section 3 of the Prevention of Terrorism Act 2005.

“ﬁnancial institution” means a commercial bank, or any other institution which makes loans advances or investments or ac- cepts deposits of money from the public.

PART A – Reporting Financial Institution 1.

Name 2.
Name 2.

Street Address ................................................................................................................... ....................................................................................................

Please type or print and select boxes and but- tons as appropriate.

3.

City/Town ....................................... 4.

State/Province ................................ 5.

Post code ......................... 6.


Country .................................................................................................... 7.

Type of ﬁnancial institution .................................................................................................... 8.

Telephone ............................... 9.

Fax ............................... 10.


Email ................................................................................................................... PART B – Reporting Period 11.

This report is for the following period: a. January to March b. April to June c. July to September d. October to December Year This is a spontaneous report as required by the Act, made upon discovering funds or property suspected of being related to a speciﬁed entity.
PART C – Checks Made of Speciﬁed Entities 12.The ﬁnancial institution named in Part A has over the reporting period made itself aware of the names and identiﬁcation details of speciﬁed entities (terrorists and terrorist organizations) pub- lished in the source(s) ticked below and compared them to the identities of its customers: (a) The Gazette of the Government of Antigua and Barbuda — Prevention of Terrorism (Security Council Resolution) Orders and amendments Prevention of Terrorism (Speciﬁed Entities Account and Property Freezing) Orders and amendments (b) The United Nations Security Council Sanctions List(s) — website sanctions lists relating to Resolution 1267(1999) and 1989(2011) website sanctions lists relating to other UN Sanctions Resolution(s) (specify): (c) Other source(s) (specify): Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES PART D – Results of Checks Appendix A 13.
The following are the results of the checks made in Part C (tick/select all appropri- ate boxes and buttons): (1) A match with the identity of a speciﬁed entity was found in the customer database.

(a) A suspicious activity report was ﬁled in relation to the customer or entity.

(b) A suspicious activity report is being prepared and will be ﬁled in relation to the customer or entity on the Suspicious Activity Report form issued by the ONDCP.
(2) A suspicious transaction was detected indicating possible links to a speci- ﬁed entity or terrorism ﬁnancing.

(a) A suspicious activity report was ﬁled in relation to the customer or entity.

(b) A suspicious activity report is being prepared and will be ﬁled in relation to the customer or entity on the Suspicious Activity Report form issued by the ONDCP.

(3) Property or funds suspected of belonging to or being held on behalf of or related to a speciﬁed entity was discovered.
(a) A suspicious activity report was ﬁled in relation to the customer or entity.

(b) A suspicious activity report is being prepared and will be ﬁled in relation to the customer or entity on the Suspicious Activity Report form issued by the ONDCP.

(4) Property or funds of a speciﬁed entity discovered in a previous reporting period continued to be held.

(a) A suspicious activity report was ﬁled in relation to the customer or entity.
(b) A suspicious activity report is being prepared and will be ﬁled in relation to the customer or entity on the Suspicious Activity Report form issued by the ONDCP.

(5) No match was found with the identify of any speciﬁed entity in the custom- er database.

(6) No suspicious transaction was detected that appeared to indicate possible links to a speciﬁed entity or terrorism ﬁnancing.
(7) No property or funds was discovered that was suspected of belonging to or being held on behalf of or related to a speciﬁed entity.

(8) No property or funds was known to be in the possession or control of the reporting institution which belonged to or was held on behalf of any speci- ﬁed entity .

PART E – Details of Funds/Property Related to Speciﬁed Entity 14. a.

Name of speciﬁed entity (terrorist or terrorist organization) to whom the funds or property relates directly or indirectly (eg.
direct or indirect ownership or control) Supervisory Authority, Antigua and Barbuda September, 2011 MONEY LAUNDERING & FINANCING OF TERRORISM GUIDELINES Appendix A b.

The following funds and/or other property related to the speciﬁed entity have been identiﬁed.

I declare the information given herein is true and correct to the best of my knowledge and belief.
Date of report: ........................................ dd-mmmm-yyyyy Name of reporting ofﬁcer: ...................................................................................

Position of reporting ofﬁcer: .................................................................................................. Signature (Sign here) X Supervisory Authority, Antigua and Barbuda September, 2011 Form issued 15 August 2011