A suspicious transaction is one that is carried out under circumstances that raise suspicion of an attempt to launder proceeds from criminal activity, or where the funds used may be intended for financing terrorism or similar activities. More detailed indicators that may suggest a suspicious transaction are specified in Section 6 of the AML Act. These include, in particular:
A transaction is always considered suspicious when:
The client, a person acting on behalf of the client, or another person involved in the transaction (known to the obliged entity), is subject to international sanctions imposed by the Czech Republic under the Sanctions Act;
The subject of the transaction is or is intended to be goods or services that are sanctioned by the Czech Republic under the Sanctions Act.
Other indicators of a suspicious transaction:
The client refuses to undergo verification or refuses to provide identification details of the person they represent;
The client behaves as if they are acting on behalf of someone else, or is accompanied or monitored by another person or persons who clearly want to remain anonymous;
The client engages in activities that may help conceal their identity or the identity of the ultimate beneficial owner;
The obliged entity has doubts about the truthfulness or completeness of the information provided by the client (e.g., it becomes apparent that the client is trying to provide inaccurate or incomplete details);
The identification documents appear suspicious or counterfeit;
The client appears nervous, reluctantly undergoes identification, or provides false information, such as regarding the origin of funds or line of business;
The client has a known criminal background or associates with individuals or groups involved in criminal activity;
The client has links to high-risk countries (e.g., their place of birth is in one of these countries; members of company bodies or shareholders are based in or originate from such countries; the assets involved are located in or will be transferred to/from these countries);
The client requests transactions that are unusual or carried out in an unusual way, or presses for urgent completion in an unusually short timeframe compared to similar transactions;
The client conducts asset transfers without any apparent economic rationale, or carries out complex or unusually large transactions;
The client performs an unusually high number of financial operations in one day or consecutive days, beyond what is typical for their activity or for comparable clients;
The funds handled by the client clearly do not match the nature or scope of their business activity or personal wealth;
The client operates in a high-risk industry prone to links with criminal organizations (e.g., erotic services, nightclubs, arms or military equipment trade, especially weapons);
The client knowingly conducts loss-making transactions or accepts unreasonably high contractual penalties;
The transaction involves a large quantity of low-value cash, or cash is unusually transported (e.g., in plastic bags, clothing pockets, etc.);
The transaction is aimed to or from regions where the client does not usually have or is unlikely to have business interests;
The transaction is carried out in amounts just below the threshold that would require mandatory client identification or verification.