# List of Reference Cases of Suspicious Transaction for Futures commission merchant

## (General Warning)

Listed below are examples of transaction to which futures commission merchant, when fulfilling the obligation for reporting of suspicious transactions as specified by Article 9 of Act on Prevention of Transfer of Criminal Proceeds, should pay special attention as a case that may constitute a suspicious transaction. Futures commission merchant shall take into account all specific information that it retains on the said transaction, including the customer attributes and circumstances at the time of the said transaction, and thereby judge whether or not respective specific transactions are suspicious transactions.

Therefore, it should be noted that although these example cases serve as a reference when futures commission merchants find or detect suspicious transactions in day-to-day transactions, all transactions which formalistically conform to any of these cases do not necessarily constitute a suspicious transaction and transactions which do not conform to these cases but are regarded as a suspicious transaction by futures commission merchants shall be subject to the requirement for the reporting of suspicious transactions.

No.1 Cases notable in relation to the matter of cash usage

(1) A transaction which large amount of money (including foreign currencies, the same shall apply hereinafter) or check is used for transaction margin or paid for settlement fund. Particular attention should be paid to transaction with excessively high value relative to the customer's income, assets, etc.

(2) A transaction which is conducted frequently within a short period of time with a large amount of payment/receipt of business margin made in cash or by check

(3) A transaction which conducted with the use of a large amount of low-value bills (including foreign currencies) for payment

No.2 Cases notable in relation to the possibility of the actual transactor being concealed

(4) A transaction whose nominee is suspected of being a fictitious or borrowed name

(5) A transaction using an account whose nominee corporation is suspected of being a "paper company"

(6) A transaction which assignor appoints agent despite lack of any rational reason such as business trip, travel or hospitalization

(7) A transaction which held by a customer who requests the sending of a transaction report etc. to a place (different from address) where difficult to contact

(8) A transaction held by an assignor who was found to hold a number of transaction accounts with other futures commission merchant

(9) A transaction held by an assignor who has no rational reason that transaction is conducted in branch located in distant place from address

No.3 Cases notable in relation to the manner of investment

(10) A transaction which traded large amount of money despite lack of usual transaction

(11) A transaction devoted large amount of share certificate to transaction margin and requested to futures commission merchant for cash out them

(12) A transaction applied large amount of bearer securities or share certificates under others name to transaction margin

(13) A transaction frequently applied share certificate etc. to transaction margin within the short period and requested futures commission merchant to cash out them

(14) A transaction remitted from financial institution account different from nominee

(15) A transaction appointed financial institution account different from nominee as beneficiary

No.4 Cases notable in relation to foreign transaction

(16) A transaction which conducted by a customer based in a country or a territory not cooperative with anti-money laundering measure or by a customer based in a country or a territory producing and exporting illegal drugs. Particular attention should be paid to cases that involve countries and territories designated by National Public Safety Commission for enhanced surveillance (The same shall apply to (17) and (18))

(17) A transaction involving a customer intends to appoint bank account of payment of profit based in a country or a territory not cooperative with anti-money laundering measures or by a person based in a country or a territory producing and exporting illegal drugs

(18) A transaction involving a customer introduced by a person (involving legal person) based in a country or a territory not coop-