We’re committed to complying fully with all applicable money-laundering laws throughout the world. We must comply with all applicable laws prohibiting money laundering. Some countries also have laws related to the reporting of cash or other suspicious transactions that we must obey.

Be alert to the following activities:

• The types of payments that have become associated with money laundering, such as: multiple money orders, travelers checks, or large amounts of cash.
  
• A customer or other third party who is reluctant to provide complete information, provides false or suspicious information, or is anxious to avoid reporting or record-keeping requirements.
  
• Unusually favorable payment terms or unusual fund transfers to or from foreign countries unrelated to the transaction.
  
• Structuring a transaction to avoid requirements, such as conducting multiple transactions below the reportable threshold amounts.
  

You must follow our rules concerning acceptable forms of payment. For further guidance on this topic, please consult with your local Legal Department.

A customer refuses to provide their address for a $3,000 money transfer to another country. Should I report this as a “suspicious person”?
Any customer reluctant to provide requested information should be reported as a “suspicious person” when processing financial transactions.

A customer asked me if I could split a $5000 transaction into two transactions of $2500 so they did not have to bother with the paperwork that may otherwise be involved. Should I process the transaction this way?
No. If it’s truly the same transaction, it should be processed as one transaction and the proper paperwork should be completely filled out and turned in to the Home Office for reporting to the government. If the customer refuses to comply, contact a member of management to assist you.