# List of Reference Cases of Suspicious Transaction report in the business of receiving postal items

1 The range of the business of receiving postal items

The business operator of receiving postal items shall be provided in Item 38 of Paragraph 2, Article 2 of "Act on Prevention of Transfer of Criminal Proceeds", indicates the business operator provide all the three services saying below in substantial.

A. Allowing providing services wherein the person authorizes a customer to use the person's residence or office address as the place at which the customer receives postal items

B. Receiving the postal items addressed to the customer substitute to the customer

C. Delivering the postal items, received for the customer

## 2 The style of possibility for suspicious transaction

Listed bellows are examples of transaction to which business of receiving postal items, when fulfilling the obligation for reporting of suspicious transaction 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.

The said business operators 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 transaction.

Therefore, it should be noted that although these example cases serve as a reference when the said business operators find or detect suspicious transactions in day-to-day transactions, all transactions which formalistically conform to any of those 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 the said business operators shall be subject to requirement for the reporting of suspicious transactions.

More, for the reporting, you may use the template of appendixes in PDF.

(1) The transaction seemed to be suggested of threat to use the services for intention to disguise the false condition of the company by the customer, encouraging giving of criminal proceeds related with money laundering and terrorist financing, etc. by the customer

(2) A transaction involving a customer who refuses to provide explanations and submit documents when requested to do so for identification of the actual beneficiary due to doubt as to whether the customer is acting on his/her own behalf

(3) The transaction the customer hopes to contract receiving postal items is in the condition of using the nominee of plural legal persons even the sole nominee

(4) The transaction sending to the customer a large amount of money frequently

(5) The transaction sending to the customer registered postal cash envelope or a telegraphic transfer by the name of business suggested to being a black market loan or "paper company"

(6) The transaction suggested to be suspicious of contracting over fictitious name or borrowed name by customer

(7) Cases where the customer insist the secrecy of the transaction unnaturally and a transaction involving a customer who tries to prevent the said business operator from reporting suspicious transaction by using force or by paying bribes

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

(9) A transaction whose circumstances are recognized by employees of the said business operators 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 thereof

(10) The transactions regarding which the Japan Financial Intelligence Center (*) and other external organizations have inquired or notified 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