The Board of the Central Bank, together with the Department for Combating Economic Crimes under the Prosecutor General's Office, adopted the Resolution dated April 3, 2023 with registration number No. 3266-3 "On additions and amendments to the rules of internal control to combat the legalization of income received from criminal activities in payment organizations, payment system operators, electronic money system operators, terrorist financing and financing the proliferation of weapons of mass destruction" (the "Resolution No. 3266-3").
According to Resolution No. 3266-3, the list of criteria and signs of suspicious transactions has been expanded and additionally include the following:
- Receipt of funds into 5 or more electronic wallets from one foreign electronic wallet (single or multiple transfers within 30 days);
- Receipt of funds into one electronic wallet from 5 or more foreign bank cards or electronic wallets (single or multiple transfers within 30 days);
- Transfer of funds from one account or electronic wallet to one or several bank cards, electronic wallets in an amount equal to or exceeding 500 base calculation values (single or multiple transfers within 30 days);
- Transfer of funds to one electronic wallet from one or several cards in an amount equal to or exceeding 500 base calculation values (single or multiple transfers within 30 days);
- Transfer of funds via a mobile application from one account (electronic wallet) to 5 or more foreign bank cards or electronic wallets (single or multiple transfers within 30 days);
- Transfer of funds from 5 or more electronic wallets to one foreign electronic wallet (single or multiple transfers within 30 days).
Moreover, individuals who have 20 or more bank cards linked to their accounts are now included in the high-risk category, and payment system operators, electronic money system operators and payment organizations will pay increased attention to them.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.