The BVI FIA is responsible for investigating and analyzing reported suspicious activities or transactions. The list of the types of activities or transactions that may give rise to suspicion of money laundering is extensive. Below are some of the activities that may arouse suspicion and be reported to the FIA:
1. Money laundering using cash transactions
- unusually large cash deposits made by an individual or company;
- substantial increases in cash deposits of any individual or business without apparent cause;
- company accounts whose transactions, both deposits and withdrawals, are denominated by cash;
- customers who seek to exchange large quantities of low denomination notes for those of higher denomination;
- frequent exchange of cash into other currencies;
- customers transferring large sums of money to or from overseas locations with instruments for payment in cash.
2. Money laundering using bank accounts
3. Money laundering involving a financial institution’s employees and agents
- customers who wish to maintain a number of trustee or client accounts which do not appear consistent with the type of business.
- any individual or company whose account shows virtually no normal personal banking or business related activities, but which is used to receive or disburse large sums which have no obvious purpose or relationship to the account holder and/or his business (e.g. a substantial increase in turnover on an account);
- matching of payments out with credits paid in cash on the same or previous day;
- large cash withdrawals from a previously dormant/inactive account, or from an account which has just received an unexpected large credit from abroad;
- companies’ representatives avoiding contact with the branch
4. Money laundering by secured and unsecured lending
- changes in employee characteristics, (e.g. lavish lifestyles or avoiding taking holidays);
- changes in employee or agent performance, (e.g. the salesman selling products for cash has a remarkable or unexpected increase in performance)
- customers who repay problem loans unexpectedly;
- requests to borrow against assets held by the institution or a third party, where the origin of the assets is not known or the assets are inconsistent with the customer’s standing.