During onboarding al Private Bank A, client C indicated that the account would be initially funded with a transfer from Bank B totaling 50 million…

The sources of funds that Bank A should conduct additional scrutiny on are the third-party transfer

and the transfer from Bank B. This is because these sources may pose higher risks of money

laundering, terrorist financing, fraud, or other illicit activities. Some of the reasons why these sources

require more scrutiny are23:

Third-party transfers may involve unknown or unrelated parties that may have ulterior motives or

hidden agendas. They may also be used to obscure the origin or destination of funds, or to

circumvent sanctions or other regulatory restrictions.

Transfers from Bank B may involve jurisdictions that have weak anti-money laundering and counter-

terrorist financing (AML/CFT) regimes, high levels of corruption, or significant criminal activity. They

may also involve banks that have poor reputation, compliance, or transparency standards.

Reference:

Third Party Payments - Wolfsberg Group

Guidance on Correspondent Banking Services - FATF