The European Union is insisting that, prior to any financial bailout of Cyprus' banks, that an investigation be conducted, to determine whether rampant money laundering exists there, as alleged by a number of sources knowledgeable about Russian Organised Crime. A private firm will conduct the investigation forthwith. This may panic money launderers operating in Cyprus to take swift action.
Should you see any large wire transfers inbound, from Cypriot banks or NBFIs, at anytime this month, you should ensure that the sender & clients are the subject of an enhanced dude diligence investigation, and that the purpose of the transfer, and the Source of Funds be also disclosed in detail. Do not accept client assurances that the transfers are being made in the ordinary course of business, for they probably are not.
Ask yourself these questions:
(1) Has your client ever received a transfer from the sender ?
(2) Has your client ever received a wire transfer from Cyprus in the past ?
(3) What type of business is the sender in ?
(4) Have you checked out the transferor bank ? What is its reputation/ownership/track record on links to criminal activity ?
Should you alert the staff in your wire room about this issue ? Absolutely; they need to notify you immediately upon receiving anything that is coming from, or began in, Cyprus.
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