From - Source of funds
A transaction must always be entered in two parts, as the funds can have as source "From" or be destined "To" an object (which may be the same object).
Here, you must therefore enter the source of funds.
The three possible object types are:
- Account
The source of funds is an account.
For the transaction types: Securities purchase, Banking domiciliation, Permanent order, E-money payment, Virtual money payment, Card payment (debit or credit), Cash withdrawal (counter), Cash withdrawal (ATM), Loan, Insurance redemption, Securities sale, Transfer
The entity and/or persons who are account holders will be entered under this account (and will therefore be linked to it).
- Person
The source of funds is a person.
For the transaction types: Money remittance, Cash deposit (counter), Cash deposit (ATM)
- Entity
The source of funds is an entity.
“Account (My Client)”, “Person (Our Client)”, “Entity (My Client)” (my_client) must be selected only when the object (person, account, entity) is:
- a client of the reporting entity and
- a suspect or a person in connection with the report.
Both conditions must be met simultaneously.
“My/Our Client” examples
- An account, held at the reporting entity, suspected of being used in order to commit a predicate offence or a a money laundering/terrorist financing offence.
- A person who is a client of the reporting entity and is suspected of having committed a predicate offence or a money laundering/terrorist financing offence.
“Account”, “Person”, “Entity” are to be used when the object:
- is not a client of the reporting entity, or
- is a client, but is not relevant to the report.
These object types “Account”, “Person”, “Entity” are considered as “Third party” in the following explanations.
“Account” examples
- an account held at another institution
- an account held at the reporting entity but unrelated to the submitted facts
- e.g. supplier accounts (electricity, gas, telecom payments)
- e.g. merchant accounts (card payments in supermarkets, clothing stores, etc.)
A transaction may be between an “My/Our Client” and a “Third party” (most common), between two “My/Our Client” objects, or even, in certain cases, within the same client (e.g. cash withdrawal, cash deposit).
Example 1:
The person, client of the reporting entity and relevant to the report, initiates a transfer from their bank account to an account held at another institution.
- From = My/Our Client
- To = Third party
Example 2:
The person, client of the reporting entity and relevant to the report, makes a withdrawal from their own account.
- From = My/Our Client
- To = Our Client
Note: The only technical difference between “My/Our Client” and “Third party” applies to the ACCOUNT object. A "My Client" account requires additional mandatory fields, compared to a "Third party" one. This means that it is mandatory for an "Our Client" account to include account data and person data related to the account in question (account holder, beneficial owner, etc.). A Third party account is considered valid only with account data filled-in.
After selecting the object for the “From” source of funds, the following window appears (the object chosen in this example is Account (My Client))
Transaction type – from_funds_code
The same transaction type must be entered in both parts of the transaction ("From" and "To")
The following transaction types can be selected:
- Securities purchase
Covers purchases of shares, bonds, or other participation in companies or investment structures.
- Other
Only to be used if the transaction type does not appear in the list e.g. options, futures.
- Currency exchange
For currency exchange operations, the Foreign currency section must be completed.
Also to be used for exchanges between virtual currencies or between virtual and fiat currencies.
- Cheque
- Banking domiciliation
- Permanent order
- E-Money payment
Covers any payment fully or partially made with E-Money.
- Virtual money
Covers any payment made with virtual currency. The EUR value must be entered, and the virtual currency amount must be entered under Foreign currency.
- Card payment (debit or credit)
- Cash withdrawal at counter (branch)
- Cash withdrawal at ATM
- Loan
This transaction type covers loan disbursements and repayments.
If the loan gives rise to suspicion, all information relating to the contract (including all contractual documents) must be provided as attachments.
- Insurance redemption
If the redemption gives rise to suspicion, all information relating to the contract (including all contractual documents) must be provided as attachments.
- Realization of a security interest
The term “security” refers, in particular, to surety agreements and various first-demand guarantees (including documentary guarantees). If the enforcement of a security gives rise to suspicion, all information regarding it (including, in particular, all contractual documentation) (all contractual documents) must be provided as attachments.
- Money remittance
Covers the transfer of cash between persons through authorized agencies.
- Night safe deposit
Instruction received through the night deposit box.
- Securities sale
The transaction type refers in particular to the sale of shares, bonds, and any other ownership interests in a company or investment structures.
- Cash deposit at counter (branch)
- Cash deposit at ATM
- Transfer
This is the most common transaction type.
How to record a transfer in goAML?
Foreign currency
If the currency of the “From” source of funds is not EUR, the Foreign currency section must be filled-in.
Conductor (if applicable proxy) – Conductor
Under this section, enter the person who actually instructed the execution of the transaction.
This may be, for example, a director of an entity or a proxy.
If this information adds no value (e.g. the ordering party is the account holder), this field may be left empty.
This section opens the natural person form: Person details
Next enter the details for the object of your choice:
Once all information concerning the “Funds originating from” has been completed, the information relating to the To - Destination of funds must be entered.
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