According to the Wolfsberg Principles on Private Banking, the bank should apply additional diligence

to customers who present a higher risk of money laundering or other financial crimes. Some of the

indicators for defining such customers are:

Persons residing in or having funds from countries with inadequate AML standards, sanctions,

embargoes, or other measures that indicate a higher risk of money laundering or terrorist

financing12.

Persons engaged in business activities known to be susceptible to money laundering, such as cash-

intensive businesses, gambling, arms trade, precious metals and stones, art and antiquities, etc13.

Persons determined to be Politically Exposed Persons (PEPs), who are individuals who hold or have

held positions of public trust or influence, or their family members or close associates, and who may

pose a higher risk of corruption, bribery, or abuse of power14.

Persons who receive funds from a correspondent banking relationship are not necessarily required

additional diligence, unless they fall under any of the above categories or other risk

factors. Correspondent banking is a service provided by one bank to another bank to facilitate cross-

border transactions, and it is subject to its own set of AML standards and due diligence measures5.

Wolfsberg Anti-Money Laundering Principles for Private Banking (2012) 1

FATF High-Risk and Other Monitored Jurisdictions

FATF Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals

FATF Guidance on Politically Exposed Persons (Recommendations 12 and 22)

FATF Guidance on Correspondent Banking Services