DISCLAIMER

Anti Money Laundering (AML) incorporates a complex of measures aimed at prevention of use of the financial system of the country or any specific financial institution for money laundering or terrorist financing. Such measures and instruments are worked out and implemented by international and national institutions, banking and business community.

VIRTACASH collects identification data of every Client, as well as IP addresses, online activity, communications and, in general, all transactions carried out by the Client.

VIRTACASH reserves the right to hold any suspicious transaction(s) originating from illegal activities, thereby requesting for additional verification documentation or channeling to appropriate government authority for necessary action.

Again, unless ordered by a Court of competent jurisdiction, VIRTACASH will not disclose information about your transaction history with any third party.


Suspicious Activities

There are signs of suspicious ctivity that suggest money laundering. These are commonly referred to as “red flags.” If a red flag is detected, additional due diligence will be performed before accepting client’s requests or providing services.

Examples of red flags are:

  • The customer exhibits unusual concern regarding the AML policies, particularly with respect to his or her identity, type of business and assets, or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspect identification or business documents.
  • The customer wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the customer’s stated business strategy.
  • The information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
  • Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
  • The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
  • The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.
  • The customer appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity.
  • The customer has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry.
  • The customer attempts to make frequent or large deposits of currency, insists on dealing only in cash equivalents.
  • For no apparent reason, the customer has multiple accounts under a single name or multiple names, with a large number of inter-account or third-party transfers.
  • The customer is from, or has accounts in, a country identified as a non-cooperative country or territory by the Financial Action Task Force.
  • The customer’s account has unexplained or sudden extensive wire activity, especially in accounts that had little or no previous activity.
  • The customer’s account shows numerous currency or cashiers check transactions aggregating to significant sums.
  • The customer’s account has a large number of wire transfers to unrelated third parties inconsistent with the customer’s legitimate business purpose.
  • The customer’s account has wire transfers that have no apparent business purpose to or from a country identified as money laundering risk or a bank secrecy haven.
  • The customer’s account indicates large or frequent wire transfers, immediately withdrawn by check or debit card without any apparent business purpose.
  • The customer makes a funds deposit followed by an immediate request that the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose.
  • The customer makes a funds deposit for the purpose of purchasing a long-term investment followed shortly thereafter by a request to liquidate the position and transfer of the proceeds out of the account.
  • The customer engages in excessive journal entries between unrelated accounts without any apparent business purpose.
  • The customer requests that a transaction be processed in such a manner to avoid the firm’s normal documentation requirements.
  • The customer, for no apparent reason or in conjunction with other red flags, engages in transactions involving certain types of securities, such as penny stocks, bearer bonds, which although legitimate, have been used in connection with fraudulent schemes and money laundering activity. (Such transactions may warrant further due diligence to ensure the legitimacy of the customer’s activity.)