The Branch Manager and AML Compliance Officer have met to discuss


The Branch Manager and AML Compliance Officer have met to discuss the rules and procedures that you have submitted and have recommended that you commence your analysis of the businesses’ customer data. They have provided you with the following additional advice for the processing of business and new customer data: A) Specifically search in the business customer and transaction data for: 

1. Proliferation type operations where a relatively new business is buying dual purpose machines (i.e., machines that can be used for both civilian and military purposes) to export items that can be used for proliferation. Search by who they are disbursing money to (Military type contractors, Nuclear, High Precision Instruments – see Part 2—Dual‑use list Defence and Strategic Goods List 2021 ( 

2. Business that has a pattern of paying off their loans in cash and transferring the money abroad in other currencies.

3. Look for cash intensive businesses operating out of the same address (CashIntensive Businesses | Dow Jones Risk & Compliance) As with Individual Customers, the alarm consisting of customer ID and related transactions is expected to be generated. 

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