# List of Reference Cases of Suspicious Transactions for Insurance Companies

## (General Warning)

Listed below are examples of transaction to which financial institutions, etc., 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. Financial institutions 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 financial institutions 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 financial institutions shall be subject to the requirement for the reporting of suspicious transactions.

### 1. Cases notable in relation to the manner of cash usage

1) A transaction involving a contract customer pays a large amount of insurance premiums with cash (including foreign currencies. The same shall apply hereinafter.) or a check. Particular attention should be paid to cases where a customer pays an excessive amount of insurance premiums relative to his or her income, assets, etc.

2) A transaction involving a customer who requests a payment of a large amount of insurance benefits or insurance premium refunds in cash or check

3) Cases where a customer makes insurance premium payments for two or more insurance contracts with a large amount paid in cash or check within a short period.

4) A payment of insurance premiums with the use of a large amount of low-value bills (including foreign currencies)

2. Cases notable in relation to the possibility of the real account holder being concealed

5) Signing of an insurance contract suspected of being concluded under a fictitious or borrowed name

6) Signing of an insurance contract with a corporate customer suspected of being a paper company

7) Signing of an insurance contract with a customer who requests the sending of the insurance policy and other certificates to an address different from the registered one.

8) Signing of an insurance contract with a customer found to have signed a number of insurance contracts

9) Signing of an insurance contract with a customer applying to conclude a contract involving the payment of a large amount of insurance premiums. Particular attention should be paid to cases where the payment of insurance premiums is made annually or in a lump sum.

10) Signing of an insurance contract with a customer who has no obvious reason for applying for insurance at the relevant branch office.

3. Cases notable in relation to the circumstances after the contract signing

11) A transaction that is abnormal from the viewpoint of economic rationality. Examples include cases where contracts are cancelled excessively early.

12) A transaction involving a customer who suddenly changes the method of paying insurance premiums from small-value monthly payments to annual payments or a lump-sum payment

13) A transaction involving a customer who suddenly switches to a high-value contract requiring payments of a large amount of premiums

4. Cases notable in relation to sales/purchases of bonds, etc.

14) A transaction in which a customer seeks to sell a large amount of bonds on condition of cash payment

15) Sales/purchases of bonds, etc. for which financial settlement is conducted with a check written by a third-party person or with a remittance made by a third-party person

5. Cases notable in relation to transactions with foreign parties

16) Signing of a contract with a customer who requests to receive insurance benefits in a country or a territory not cooperative with anti-money laundering measures or a country or a territory producing and exporting illegal drugs or with a customer who requests to receive insurance premium refunds therein. Particular attention should be paid to cases involving countries and territories designated by the FSA for enhanced surveillance (The same shall apply to 17) and 18).