# List of Reference Cases of Suspicious Transactions for Credit Card Business Operator

### 1. General Warning

Listed below are examples of transaction to which credit card business operator, when fulfilling the obligation for reporting of suspicious transactions as specified by Article 9 of the Act on Prevention of Transfer of Criminal Proceeds, should pay special attention as a case that may constitute a suspicious transaction. Credit card business operator 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 Credit card business operators 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 Credit card business operator shall be subject to the requirement for the reporting of suspicious transactions.

### 2. List of Reference of Suspicious Transactions

(1) A transactions with customer who requests several credit cards within a short period or requests for reissue by frequent loss.

(2) Transactions with customer who requests to raise available value and not suit his/her income or asset

(3) Credit card contract suspected of being concluded under a fictitious or a borrowed name

(4) Credit card contract suspected of being dummy company

(5) Despite lack of any rational reasons, a customer who requests the sending of a credit card to an address different from the registered one or a customer who declines receiving notices, etc. of transaction.

(6) A transaction with customer who pays large amount of money within a short period and reaches the available value.

(7) A transaction with customer who frequently purchases alternatives such as large amount of gift card or coupon etc. by credit card

(8) A transaction with customer who frequently changes an account for withdrawing payment

(9) Cases which suspected that credit card is being used by different from nominee.

(10) Transaction involving a customer who refuses to submit material or explanation despite beneficiary is confirmed because there is suspicious that customer receives or uses credit card on his/her own behalf. The same shall apply to cases where a transaction is conducted by an agent and where there is suspicion that a person other than the customer is the beneficiary.

(11) A transaction involving a customer who attaches unduly high importance to transaction confidentiality or a customer who has requested the credit card business operator not to report his or her transaction or who tries to prevent the financial institution from reporting it by using force or by paying bribes.

(12) A transaction involving a member of an organized crime group or a person associated therewith.

(13) A transaction whose circumstances are recognized by employees as unnatural in light of their knowledge and experiences and a transaction involving a customer whose attitude or behavior is recognized as unnatural in light of thereof.

(14) Transactions regarding which the Japan Financial Intelligence Center (*) and other external organizations have inquired or notified the credit card business operator due to the possibility of involving criminal profit

$ ^{*} $ The Japan Financial Intelligence Center (JAFIC) is attached to the Organized Crime Control Department, Criminal Investigation Bureau of the National Police Agency.