# List of Reference Cases of Suspicious Transactions for Depository Financial Institutions

## (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) Transactions involving the use of a large amount of cash (including foreign currencies. The same shall apply hereinafter.) or checks for payment/receipt (including sales/purchases of securities, remittances and exchanges. The same shall apply hereinafter.). Particular attention should be paid to transactions with excessively high value relative to the customer's income, assets, etc. and transactions conducted in cash when the use of a remittance or a check seems to be reasonable.

2) Transactions which are conducted frequently within a short period of time with a large amount of payment/receipt made in cash or by check.

3) Transactions conducted with the use of a large amount of low-value bills (including foreign currencies) for payment or exchange

4) Depositing of a large amount of cash in a night deposit box or a transaction involving a rapid increase in the amount of funds used

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

5) Payment/receipt using an account suspected of being opened under a fictitious name or a borrowed name

6) Payment/receipt using an account whose nominee corporation is suspected of being a paper company

7) Payment/receipt using an account held by a customer who requests the sending of a cash card to an address different from the registered one or a customer who declines receiving notices.

8) Payment/receipt using an account held by a customer who was found to hold a number of accounts, including the case where the customer holds a number of accounts under different names with store names attached

9) Payment/receipt using 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 account usage

10) A transaction involving an account through which payment/receipt is conducted in large amount or frequently within a short period of time after it is opened but which is closed later or through which no transaction is conducted later.

11) A transaction involving an account through which a large amount of payment/receipt is made frequently

12) Remittance of cash made immediately after the cash is withdrawn from the account (including the case where the transaction is recorded as a cash transaction for the purpose of paperwork). Particular attention should be paid to the case where the remittance is made under a name different from the nominee of the account from which the cash was withdrawn.

13) A transaction involving an account through which remittance is made to a number of persons frequently. Particular attention should be paid to the case where a large amount of payment is made into the relevant account immediately before remittance is made.

14) A transaction involving an account to which remittance is made by a number of persons frequently. Particular attention should be paid to the case where a large amount of money is remitted or withdrawn from the relevant account immediately after remittance is made thereto.

15) A transaction involving an account to which remittance is made anonymously or under a name suspected of being a fictitious one

16) A transaction involving an account through which there is no fund movement usually but through which a large amount of