I am of the opinion that this approval is sufficient to satisfy this matter as well.
- In summary, I am of the opinion that from the above details it is clear that in the framework of the legal proceeding, when the plaintiffs were given the opportunity to transfer the documents requested by the bank, they transferred documents that were sufficient to remove the concrete and relevant suspicions that arose from the management of their accounts to the sending of the closure notice to the accounts.
It should be emphasized that there may be substance to the bank's claims that even after the legal proceeding, there remains a lack of clarity regarding various issues related to the plaintiffs' activity. However, as will be detailed below, the issues that remain unclear, to the extent that they exist, almost all of them revolve around claims that were first raised in the framework of the legal proceeding, and therefore it is clear that the plaintiffs did not have the full opportunity to deal with them. Moreover, and this is the main importance - with regard to all the issues that remain completely unclear, it is possible that the Bank presented and detailed a certain lack of clarity, but the Bank did not specify a concrete concern stemming from the lack of clarity. In this context, as detailed at length in the framework of the normative chapters, questions or lack of clarity may raise red flags, but this is not the case, since the Bank must show what concrete suspicions are relevant that can be based on these red flags. More precisely, red flags in activity are sufficient to require the taking of risk-preventing actions, including monitoring actions of the customer and increased control over him, and obligations to report the customer to the competent authorities, but they are not sufficient to establish grounds for closing the account, as long as the bank does not show a connection between such a red flag and suspicion of money laundering or terrorist activity. Thus, for example, the red flags that are flown as a result of incorporation in offshore countries can establish suspicion of money laundering activity, red flags that call customers in enemy countries can establish suspicion of terrorist activity, and red flags related to illegal activity - such as drug trafficking or binary options (to the extent that it is banned). However, in the case before me, at the end of the proceeding, the bank points to questions that have not been fully clarified, but it does not point to concrete suspicions that exist in these questions or red flags, in order to establish them.