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Co-Mingling of Funds

It was reported to FMU that large volumes of credits were made in the account of person ‘X’. The funds were then debited from the account on same day/next day. It was also observed that most of transactions were related to Foreign Currency Encashment i.e., person ‘X’ made encashment from his US Dollar account into PKR and the same were then credited in his PKR  account. Afterwards, he made cash withdrawals below CTR threshold from his PKR account on same day or next day. The purpose of these transactions was not provided to the bank.

During analysis, it was observed that no significant activity was observed in his PKR account since inception of account on 13-10-2009 till an online credit transfer of relatively higher value from an entity’s  account was made on 19-07-2012. After that, significantly high value transactions were noted in his PKR account during the months of September and December 2012. The entity’s account was searched in FMU’s internal database and several CTRs were found under the title of Exchange Company.

In addition to above, large amount of funds were transferred in his PKR account from his US Dollar Account as intimated by the bank.

The account holder was probably trying to mingle the proceeds from Exchange Company business with his savings in the personal account to understate the business income or to camouflage the proceeds. Financial information was, therefore, disseminated to State Bank of Pakistan citing  possible attempt to circumvent the rules involving Exchange Company business; structuring of transactions; and intermingling the suspected business proceeds.


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