"The business service provider is aware that the customer has previous convictions for money laundering offenses or source offenses, or that he is under investigation regarding these offenses..."
"The source of the funds is financial institutions, corporations that have been established, or persons residing in a country at risk or in offshore countries. The financial activity does not correspond to the details of the business service provided/agreed upon (frequency, time, means of payment, etc.) without any business reason or logic."
Also relevant are the red flags as follows, which were determined in the Supervisor of Banks' document:
the establishment of another active company with a similar name in another country; multiple transfers of substantial amounts to offshore countries and vice versa; circular movements in which funds are reinvested in the country of origin after being deposited in a foreign country (often offshore); The action in the account is not typical of the customer's profile, such as the management of business activity in the account that was not opened for this purpose or the scope of activity that does not match the information provided by the customer when opening the account; Accounts of foreign residents, including a power of attorney who is a resident of Israel; Accounts in the name of a company incorporated in an offshore that is controlled by an Israeli resident or whose authorized signatory to the account is an Israeli resident.
- the risk mitigation stage;
Increased control, monitoring and monitoring - At the risk reduction stage, the banking corporation is required, first and foremost, to carry out control actions, to monitor its customers and their activities and, if necessary, to resume the Know Your Customer procedure. In this framework, and in order to implement its obligations, the bank is entitled to demand additional documents and information from the customer in order to dispel the suspicions that arise in connection with its activity.