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#2275532 - 09/13/22 09:47 PM Terrorist Financing?
Anonymous
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We use a third-party AML software that assesses various risks. We received an alert on an account that has a lot of not-card-present transactions out of Nigeria. The alert is for possible terrorist financing.

What on earth do I do with this? I have no way of knowing if any of these companies are fronts. Google search has revealed very little, if anything, about the names of the merchants and any possible ties to nefarious activity. I know that the cardholder is not in Nigeria. Nothing else causes concern-- it is just simply the location of these online purchases.

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#2275533 - 09/14/22 11:19 AM Re: Terrorist Financing? Anonymous
edAudit Offline
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edAudit
Joined: Jul 2008
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There should be a procedure that addresses this. If not that would be the first step,

You need to find out more about the customer and possibly increase the risk rating. What are they purchasing. Why Nigeria. Where are the products being shipped. Are the transaction legit or was there an account take over. Did someone ask the client?
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#2275546 - 09/14/22 02:15 PM Re: Terrorist Financing? Anonymous
Rocky P Offline
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Joined: Jun 2003
Posts: 7,659
Florida
If you don't get a response you are comfortable with, block the account to foreigh business. That would solve the immediate problem
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#2275557 - 09/14/22 04:35 PM Re: Terrorist Financing? Anonymous
ACBbank Offline
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ACBbank
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New York City
There is no way to know if this is TF based on the information you presented. If you're not comfortable with the transactions, shut down the account.
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#2275625 - 09/15/22 06:28 PM Re: Terrorist Financing? Anonymous
Anonymous
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Whether or not this is terrorist financing aside, a US-based customer making purchases from what sounds like several Nigerian merchants seems unusual. I would find out what the customer is doing, and treat that answer with a hefty amount of skepticism if it doesn't make sense. Whatever they explain their purchasing, do those merchants seem reasonable and would it make sense to make purchases in those dollar amounts? Especially if it's for physical goods that would be shipped overseas? Or is this just some scheme to transfer money overseas while avoiding funds transfer recordkeeping requirements?

Just because your alert says one thing doesn't mean that's what your ultimate SAR, if one is produced, needs to conclude.

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