# List of Reference Cases of Suspicious Transactions for Securities Companies, etc.

## (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) Investment made in stocks, bonds, investment trusts, etc. with the use of a large amount of cash (including foreign currencies. The same shall apply hereinafter.) or checks. Particular attention should be paid to a transaction with an excessively high value relative to the customer's income, assets, etc.

2) Investments in stocks, bonds, investment trusts, etc. which are made frequently within a short period of time with a large amount of transactions conducted in cash or checks

3) Investment made in stocks, bonds, investment trusts, etc. 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

4) Sales/purchases of stocks and bonds and investment in investment trusts, etc. conducted with the use of an account suspected of being opened under a fictitious or borrowed name

5) Sales/purchases of stocks and bonds and investment in investment trusts, etc. conducted with the use of an account whose nominee corporation is suspected of being a paper company

6) Sales/purchases of stocks and bonds and investment in investment trusts, etc. conducted with the use of an account held by a customer who requests the sending of documents such as trading reports to an address different from the registered one.

7) Sales/purchases of stocks and bonds and investment in investment trusts, etc. conducted with the use of an account held by a customer who was found to hold a number of accounts.

8) Sales/purchases of stocks and bonds and investment in investment trusts, etc. conducted with the use of an account held by a customer who has no obvious reason for doing transactions at the relevant branch office

### 3. Cases notable in relation to the manner of investment

9) A transaction involving an account through which no transaction is conducted usually but through which a large amount of investment is made suddenly

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

11) A transaction involving such a large amount of bearer securities or stocks registered under the names of persons other than the customer as to create doubt as to whether they are really held by the customer

12) A transaction in which a customer frequently seeks to sell stocks, etc. within a short period of time on condition of cash payment

13) A transaction 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

14) A transaction involving a customer who seeks to designate a bank account opened under the name of a third-party person as the payment destination

### 4. Cases involving custody

15) Cases where attention should be paid to the circumstances at the time of the signing of contracts are similar cases cited in "2. Cases involving the possibility of the real account holder being concealed" above.

16) A transaction involving a customer who requests delivery of securities without the use of the custody system for no rational reason when buying a large amount of stocks or bonds.