A. Customer due diligence and tipping-off
1. If, during the establishment or course of the customer relationship, or when conducting occasional transactions, a financial institution suspects that transactions relate to money laundering or terrorist financing, then the institution should:
(a) normally seek to identify and verify the identity [Reliable, independent source documents, data or information will hereafter be referred to as "identification data."] of the customer and the beneficial owner, whether permanent or occasional, and irrespective of any exemption or any designated threshold that might otherwise apply; and
(b) make a suspicious transaction report (STR) to the financial intelligence unit (FIU), in accordance with Recommendation 20.
2. Recommendation 21 prohibits financial institutions, their directors, officers and employees from disclosing the fact that an STR or related information is being reported to the FIU. A risk exists that customers could be unintentionally tipp
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