NFIU XML Reporting Instructions and Specifications

NFIU XML Reporting Instructions and Specifications

Version 4.5

Last Update: 14-Jan-2021

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NFIU XML Reporting Instructions and Specifications

Revision History

Re Date Author Description Requestor v 2.1 May 19, 2008 T. Breineder Combined STR and CTR schemas Maher Abu Ghali

2.2 June 04, 2008 M Abu Ghali Finalized version for the FIC Namibia FIC - BON 2.3 June 06, 2008 T. Breineder Moved local currency element from Maher Abu Ghali the transaction details to the report element 2.4 June 06, 2008 T. Breineder Amended account holder to include a Maher Abu Ghali flag specifying the primary signatory 2.4.1 June 23, 2008 M. Abu Ghali Account Balance element added to Maher Abu Ghali t_account node 2.4.2 July 30, 2008 Ameen Safadi 2.4.3 August 28, 2008 M. Zeeshan Tahir Teller in Transaction was made Badi Alkhatib optional. Differences between schema & documentation rectified. 2.4.4 August 29,2008 Stefan Brezina Consistency check and rework Badi Alkhatib 2.4.4 September 12, 2008 Ameen Safadi Remove Entity Type lookup table from document, and clean some unused lookup values. No change in schema. 2.4.5 November 03, 2008 Zeeshan Tahir All date fields are bound to have Ameen Safadi values later than or equal to 1900-01- 01 2.4.6 November 05, 2008 Zayeem Khan Several non-mandatory elements can Ameen Safadi now have blank values. t_person/identification node can now be repeated. City field can be up to 255 chars. Phone number can be up to 50 chars. rentity_id > =1. IBAN length was raised to 34. 2.5 May 05, 2009 Zayeem Khan Introduction of new nodes to mark Maher Abu Ghali my_client in the “from” and “to” sides of transactions. Node for “gender” added to person node. Pattern restriction removed from type "email_address". Maxlength set to 255 for node "incorporation_state". Revamped the whole document to have updated figures as per the latest schema, restructured some parts of the document, recreated all the broken links within the document and checked for correctness and completeness of the document as per the schema. 2.6 June 03, 2009 Scott Fulford Several nodes under the various Maher Abu Ghali ‘my_client’ types from schema 2.5 have been made mandatory in 2.6 3.0 Jan. 07, 2010 Ameen Safadi Modify the document to reflect all the Maher Abu Ghali new features of schema 3.0 3.1 May. 18, 2010 Ameen Safadi Add new elements: fiu_ref_number, Maher Abu Ghali transation_location, transaction_description 4.5 Jan. 31, 2013 Ameen Safadi Schema upgrade to release 4.5. Maher Abu Ghali

4.5 Dec. 06, 2019 Obilana Olayiwola Schema upgrade to release 4.5 Adegbolahan Olugbemi

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Table of Contents List of Figures ...... 5 List of Tables ...... 6 Acronyms ...... 7 1. Summary...... 8 2. Conventions used in this document ...... 8 3. Description of XML Nodes ...... 9 3.1 Node “report” ...... 9 3.1.1 Subnode report_indicators ...... 11 3.2 Node transaction ...... 11 3.2.1 Node t_from_my_client ...... 14 3.2.2 Node t_from ...... 15 3.2.3 Node t_to_my_client ...... 17 3.2.4 Node t_to ...... 18 3.2.5 Subnode goods_services ...... 19 3.3 Node Activity (New in Schema 4.5) ...... 21 4. Description Of Common Types Used in the Schema ...... 22 4.1 Type t_account_my_client ...... 22 4.2 Type t_account ...... 25 4.3 Type t_entity_my_client ...... 28 4.4 Type t_entity ...... 30 4.5 Type t_person_my_client ...... 32 4.6 Type t_person ...... 35 4.7 Type t_party ...... 39 4.8 Type t_address ...... 40 4.9 Type t_phone ...... 41 4.10 Type t_foreign_currency ...... 42 4.11 Type t_person_identification ...... 42 4.12 Type report_party_type ...... 43 5. Lookup Values...... 45 5.1 Submission type – goAML Enumeration ...... 45 5.2 Funds type ...... 45 5.3 Account type ...... 45 5.4 Account status type ...... 46 5.5 Identifier type ...... 46 5.6 Conduction Type ...... 46 5.7 Transaction Item Status ...... 46 5.8 Report Code – goAML Enumeration ...... 47 5.9 Contact Type ...... 47 5.10 Communication Type ...... 47

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5.11 Entity Legal Form Type ...... 48 5.12 Transaction Item Type ...... 48 5.13 Currencies - Enumeration ...... 48 5.14 Country Codes - Enumeration ...... 55 5.15 account_person_role_type ...... 61 5.16 entity_person_role_type ...... 62 5.17 Party Role type ...... 62 5.18 Entity type ...... 62 5.19 indicator_type ...... 63 5.20 Gender type ...... 82

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List of Figures

Figure 1: Overview node "report" ...... 9 Figure 2:Overview Node "transaction” ...... 11 Figure 3: Overview node "t_from_my_client" ...... 14 Figure 4: Overview node" t_from" ...... 15 Figure 5: Overview node "t_to_my_client" ...... 17 Figure 6: Overview node "t_to"...... 18 Figure 7: Overview subnode "goods_services" ...... 19 Figure 8: Overview node "activity" ...... 21 Figure 9: Overview type "t_account_my_client" ...... 22 Figure 10: Overview type" t_account" ...... 25 Figure 11: Overview type "t_entity_my_client"...... 28 Figure 12: Overview type "t_entity" ...... 30 Figure 13: Overview type "t_person_my_client" ...... 32 Figure 14: Overview type "t_person" ...... 35 Figure 15: Overview type "t_party" ...... 39 Figure 16: Overview type" t_address" ...... 40 Figure 17: Overview type "t_phone" ...... 41 Figure 18: Overview type" t_foreign_currency" ...... 42 Figure 19: Overview type "t_person_identification" ...... 43 Figure 20: Overview type "report_party_type" ...... 44

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List of Tables

Table 1: Details “node Report” ...... 10 Table 2: Details subnode "report_indicators" ...... 11 Table 3: Details node "transaction" ...... 12 Table 4: Details node "t_from_my_client" ...... 15 Table 5: Details node" t_from" ...... 16 Table 6: Details node" t_to_my_client" ...... 17 Table 7: Details node "t_to" ...... 18 Table 8: Details subnode "goods_services" ...... 20 Table 9: Details node "activity" ...... 21 Table 10: Details type "t_account_my_client" ...... 24 Table 11: Details type "t_account" ...... 27 Table 12: Details type "t_entity_my_client" ...... 29 Table 13: Details type "t_entity" ...... 31 Table 14: Details "type t_person_my_client" ...... 34 Table 15: Details type "t_person" ...... 38 Table 16: Details type "t_party" ...... 40 Table 17: Details type "t_address" ...... 41 Table 18: Details type "t_phone"...... 41 Table 19: Details type "t_foreign_currency" ...... 42 Table 20: Type "t_person_identification" ...... 43 Table 21: Type "report_party_type" ...... 44 Table 22: Submission type ...... 45 Table 23: Funds type ...... 45 Table 24: Account type ...... 46 Table 25: Account status type ...... 46 Table 26: Identifier type ...... 46 Table 27: Conduction Type ...... 46 Table 28: Transaction Item Status ...... 47 Table 29: Report Code...... 47 Table 30: Contact type...... 47 Table 31: Communication Type ...... 47 Table 32: Legal Form Type ...... 48 Table 33: Transaction Item Type...... 48 Table 34: Currency Codes ...... 49 Table 35: Country Codes ...... 61 Table 36: Account_person_role_type ...... 62 Table 37: Entity_person_role_type ...... 62 Table 38: Party Role type ...... 62 Table 39: Entity type ...... 62 Table 40: Indicator type ...... 81 Table 41: Gender Type ...... 82

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Acronyms

AIF – Additional Information File ATM – AUTOMATED TELLER MACHINE BVN – Bank Verification Number CTR – Currency Transaction Report FIU – Financial Intelligence Unit goAML – Government Office Anti Money Laundering IBAN – International Bank Account Number ID - Identity ISO CODE – International Organization of Standardization KYC – Know Your Customer NFIU – Nigerian Financial Intelligence Unit NSI Indicator Code – Nationwide SAR Initiative PND – Post No Debit RC NO – Registered Company Number RE – Reporting Entity SAR – Suspicious Activity Report SSN – Social Security Number STR – Suspicious Transaction Report SWIFT CODE - Society for Worldwide Interbank Financial Telecommunication XML – Extensible Markup Language

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1. Summary

The purpose of this specifications document is to provide both the reporting entities and reporting persons with the requirements and conditions for creating compatible XML files using the provided XML- Schema for the different supported report types.

A report file contains the following information which can be represented in the goAML Client after uploading and verifying the XML file.

• Basic information about the report. • Where does the money come from. • Who conducted the transaction. • Where does the money go to. • Was the transaction related to a property transfer • Who reported the transaction(s) (Optional) • What was the reason for the report and which actions have been taken (Optional) • In multi-party transactions, list of all involved parties and their respective roles in the transactions.

An XML report is linked to one Reporting Entity but may contain multiple transactions. An uploaded report can be from ONE report type.

This document will provide a reference to the schema, nodes and types as well as the lookup tables for enumeration values. (e.g. Country Codes)

2. Conventions used in this document

The following conventions are used in this document:

Required field

Required, 1 to N values

Optional field

Optional sub node

Required sub node

Optional, but one of the two nodes should be provided

Integer A 32 bit value Date time A date and time value in the following format: YYYY-MM-DDTHH:MM:SS Sequence to sub nodes

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3. Description of XML Nodes

3.1 Node “report”

Basic information about Reporting Entity, reporting date and type of report. It can contain multiple transactions.

Figure 1: Overview node "report"

Name Description Length Req. Example

rentity_id Reporting Entity number Integer Y 1237

defined by FIU >= 1

rentity_branch Branch of current reporting 255 N Branch of Western

entity. Union whom reported

the transactions

submission_code Type of submission Enumeration Y See 5.1 Submission

type

report_code Type of transaction Enumeration Y

(STR/CTR)

See 5.8 Report Code

entity_reference Optional reference to the 255 N STR Rep 392

report, used by reporting

entity

fiu_ref_number Optional ref. number to be STR_20100217. FIU (New in Schema 3.1) used as communication 255 N requests more info

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channel between the FIU regarding a report, so and the Reporting Entity RE can use that number in their reply submission_date Submission date and time Datetime Y 2006-03-25T11:55:00

Type “Currency- currency_code_local Local Currency code type” Y EUR

Can be forced mandatory in certain report types by using the new goAML Full details of the report’s Type feature: “XML reporting_person reporting person “t_person” Y Rejection Rules”

Describes location of the Type Mandatory: Same as Location reported report “t_address” N “reporting person”

Why the report was reported Mandatory: Same as Reason (especially for STRs) 4000 N “reporting person”

Describes action related to Mandatory: Same as action the report 4000 N “reporting person”

Type See 3.2 Node transaction Transaction information transaction Y transaction

Involved subjects and items list linked directly to report. Type Activity New in 4.5 “Activity” Y See 3.3 Node activity

List of indicators for the current reports. Please use only the enumerations from the list provided. For CTR and AIF reports, please use Type 1..man See 3.1.1 Subnode report_indicators the NSI indicator code. “indicator” y report_indicators

Table 1: Details “node Report” As of schema 4.5. Report could contain either a list of transactions as it was always or a list of involved subjects without the need of a transaction to link them.

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3.1.1 Subnode report_indicators

Figure 2: Overview subnode report_indicators

Name Description Length Req. Example indicator Some 25 Y Crime, classification for Terror Funding, etc. the report (FIU predefined list of codes)

Table 2: Details subnode "report_indicators"

3.2 Node transaction

Figure 2:Overview Node "transaction”

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Name Description Length Req Example . transactionnumber Unique transaction number 50 Y 20084711 for bank transaction Internal_ref_number Reporting Entity internal 50 N WU_BRNCH01_0001 transaction reference number transaction_location Branch/Location where the 255 Y Branch 001 (New in Schema 3.1) transaction took place transaction_description Free text field to describe 4000 Y (New in Schema 3.1) the purpose of the transaction date_transaction Date and time of the DateTime Y 2006-03-25T11:55:00 transaction teller Who conducted the 20 N ID88933345 transaction authorized Who authorized the 20 N ID00033345 transaction late_deposit and date_posting are both optional but when setting date_posting, late_deposit becomes mandatory. 3 possible combinations 1. none of the nodes is set 2. only late_deposit is set 3. late_deposit AND date_posting are set late_deposit Late deposit indicator Boolean Y/N True date_posting Date of posting (if different DateTime N 2006-03-24T19:55:00 from date of transaction) value_date Value date DateTime N 2006-03-27T00:00:00 transmode_code How the transaction was Enumeration Y See 5.6 Conduction conducted Type transmode_comment Description if 50 N - transmode_code is “O” (Other) amount_local The value of the transaction Decimal Y - in local currency Table 3: Details node "transaction" Transaction could be either a bi-party transaction with clear From and To sides, or a multi-party transaction with unlimited list of subjects (Persons, Accounts and Entities) where each has a role in the transaction rather than a clear from or to side. Bi-Party Transaction One of the nodes t_from_my_client or t_from should be provided. Both CANNOT be present together in a transaction, but one of them should be present. t_from_my_client Specifies where the money Subnode See 3.2.1

came from. If the source is t_from_my_client Y

reporting bank’s client, then (one of this node should be provided

t_from Specifies where the money Subnode them) See 3.2.2 Node

came from t_from

One of the nodes t_to_my_client or t_to should be provided. Both CANNOT be present

together in a transaction, but one of them should be present.

t_to_my_client Specifies where the money Subnode See 3.2.3 Node

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Y

went. If the destination is t_to_my_client

reporting bank’s client, then (one

this node should be provided of

them) t_to Specifies where the money Subnode See 3.2.4 Node t_to

went.

Multi-Party Transaction

Please don’t use

party Describes the involved party Type Y See 4.7 Type

details “t_party t_party

”

Goods_services The goods/services linked to the subnode N See 3.2.5

transaction Subnode

goods_services

Comments Generic comments field 4000 N

Table 3: Details node transaction

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3.2.1 Node t_from_my_client

This node should be provided if the source side of the transaction is a client of the reporting bank. As on schema 4.5, entity could be a direct party in bi-party transactions

Figure 3: Overview node "t_from_my_client"

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Name Description Length Req. Example

from_funds_code Type of funds used Enumeration Y See 5.2 Funds type

in initiating

transaction

from_funds_comment Description, if 255 N -

funds_code is “O”

(Other).

from_foreign_currency If the transaction is type N See 4.10 Type

conducted in foreign t_foreign_currency t_foreign_currency

currency, then

specify the foreign

currency details.

t_conductor The person type N See 4.5 Type

performing the t_person_my_client t_person_my_client

transaction.

from_account Subnode that holds type See 4.1 Type

account information t_account_my_client t_account_my_client

Y from_person Subnode that holds Type See 4.5 Type

“from person” t_person_my_client (one t_person_my_client

of information.

them from_entity Subnode that holds Type See 4.3 Type only) New in Schema 4.5 “from entity” t_entity_my_client t_entity_my_client

information.

from_country Country where Enumeration Y See 5.14 Country

transaction was Codes

initiated.

Table 4: Details node "t_from_my_client"

3.2.2 Node t_from

Source of the transaction. Can be either a person, an account or an entity. In case of a person source, as per Schema 3.0, the conductor could be different from the source person. As per schema 4.5,the entity could be a direct party in bi-party transactions

Figure 4: Overview node" t_from"

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Note: Bi-directional transactions are composed of a source and destination. The source and destination may be either a person, an account or an entity (As per schema 4.5). For account deposits, the source is a person and the destination is an account i.e. on t_from side we will have from_person and on the t_to side we will have t_to_account. For account withdrawals, we will have from_account at the t_from side and to_person at the t_to side. For money remittances, we will have person to person transactions i.e. from_person at the t_from side and to_person at the t_to side. The same structure of person to person transactions can be used for any money service type of transaction. For account transfers, we will have account to account transactions i.e., from_account at the t_from side and to_account at the t_to side.

Name Description Length Req. Example from_funds_code Type of funds used Enumeration Y See 5.2 Funds in initiating type transaction from_funds_comment Description, if 255 N - funds_code is “O” (Other). from_foreign_currency If the transaction is type N See 4.10 Type conducted in foreign t_foreign_curren t_foreign_currenc currency, then cy y specify the foreign currency details. t_conductor The person type N See 4.6 Type performing the t_person t_person transaction.

from_account Subnode that holds type “t_account See 4.2 Type account information t_account from_person Subnode that holds type See 4.6 Type “from person” “t_person” Y t_person information. (one of them) from_entity Subnode that holds type “t_entity” See 4.4 Type New in Schema 4.5 “from entity” t_entity information. Table 5: Details node" t_from"

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3.2.3 Node t_to_my_client

This node should be provided if the destination side of the transaction is a client of the reporting bank.

Figure 5: Overview node "t_to_my_client"

Name Description Length Req. Example to_funds_code Disposition of funds Enumeration Y See 5.2 Funds type to_funds_comment Description, if funds_code is 255 N - “O” (Other) or policy number. to_foreign_currency If the transaction is conducted in type N See 4.10 Type foreign currency, then specify t_foreign_cur t_foreign_curr the foreign currency details. rency ency to_account Subnode that holds account type See 4.1 Type information t_account_m t_account_my y_client _client to_person Subnode that holds person type Y See 4.5 Type information t_person_my (one of t_person_my_ _client them) client to_entity Subnode that holds “to entity” Type See 4.3 Type New in Schema 4.5 information. t_entity_my_ t_entity_my_cl client ient to_country Target country of the Enumeration Y See 5.14 transaction Country Codes Table 6: Details node" t_to_my_client"

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3.2.4 Node t_to

Information about the transaction disposition(s) - i.e. where the money went. t_to can either point to a person or to an account.

Figure 6: Overview node "t_to"

Name Description Length Req. Example

to_funds_code Disposition of funds Enumeration Y See 5.2

Funds type

to_funds_comment Description, if funds_code is 255 N -

“O” (Other) or policy number.

to_foreign_currency If the transaction is conducted in type N See 4.10 Type

foreign currency, then specify t_foreign_curr t_foreign_cur

the foreign currency details. ency rency

to_account Subnode that holds account type t_account See 4.2

information Type

t_account Y to_person Subnode that holds person type t_person See 4.6

(one of information Type

them) t_person

to_entity Subnode that holds “to entity” Type t_entity See 4.4

New in Schema 4.5 information. Type t_entity

to_country Target country of the Enumeration Y See 5.14

transaction Country

Codes

Table 7: Details node "t_to"

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3.2.5 Subnode goods_services

Figure 7: Overview subnode "goods_services"

Name Description Length Req. Example Item_type Lookup code Type Y C = Car describes the item “trans_item_type” L = Land type Item_make Item Maker 255 N In case of Car for example, BMW description Text 4000 N Apartment building previously_registered_to Name of previous 500 N John Smith owner presently_registered_to Name of current 500 N Jane Smith owner estimated_value Estimated value of Decimal N 250000.00 the property – Used Currency is

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the one specified in node from_currency status_code Status code Enumeration N See 5.7 Transaction Item Status status_comments Status Comments 500 N disposed_value effective value for Decimal N 500000.00 property transfer – Used Currency is the one specified in node from_currency Currency_code used to report Enumeration N See 5.13 (New in Schema 3.1) service conducted Currencies in foreign currency size Size of the Decimal N 150 property – in unit specified in node size_uom size_uom Unit of 250 N Square meters measurement address Address of the type t_address N See 4.8 Type property t_address registration_date Official DateTime N 2001-12- registration date 17T09:30:47 registration_number Official 500 N Car VIN registration Number number Identification_number Any number that 255 N Car Plate can identify the Number item Comments Additional 4000 N comments

Table 8: Details subnode "goods_services"

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3.3 Node Activity (New in Schema 4.5)

A new feature of schema 4.5. Reports can now include an activity node to represent an event where a list of subjects and goods are related directly to the report without the need of a transaction.

Figure 8: Overview node "activity"

Name Description Length Req. Example report_parties Represents a Y collection of involved subjects an involved subject with its details report_party Represents a single Type Y See 4.12 Node involved subject report_party_type report_party_type with its details. At least one party should be included. goods_service The standard Type t_trans_item N - goods_services node available in previous schemas Table 9: Details node "activity" .

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4. Description Of Common Types Used in the Schema

Type t_account_my_client 4.1 The structure of this type is similar to that of type t_account, with some added restrictions i.e. some nodes which are not mandatory in t_account may be mandatory in t_account_my_client. These restrictions are defined by the local FIU. The logic here is that whenever the involved account or person is the client of the reporting entity, more details may be demanded on the client, and the reporting entity must have the information as part of the adherence to the “Know Your Customer” (KYC) philosophy of compliance.

Figure 9: Overview type "t_account_my_client"

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Name Description Length Re Example

q.

Instituation_name Bank of … The name of the Bank 255 Y

(New in Schema 3.0) institution_code Y - Institution code 50

(one

swift SWIFT code according to 11 of ATTBVI

ISO 9362 the

m)

Non_banking_inst A flag to cover cases where Boolean N Investment company

itution the account belongs to non-

(New is Schema 3.0) banking institution Branch Y ABX12 Branch code or name 255

(enlarged in vesion. 3.1 to 255 chars)

Account Y 31032027088 Account number 50

(enlarged in vesion.

3.1 to 50 chars)

currency_code Currency the account is kept Enumeration Y See 5.13 Currencies

in

account_name This is a free text field used 255 Y Private savings account

(enlarged in 3.1 to to “Label” the account, for example a saving book 255 chars)

account with anonymous owner, or an Entity account

dedicated to Invoices, etc.

iban N IBAN 34 LT601010012345678901 Please provide BVN in place Accepts only 11 client_number Y 31032027088 of client_number. digit number (30) personal_account Y See 5.3 Account type Account Type Enumeration _type

t_entity N See 4.4 Type t_entity Business entity owning the type

account t_entity

signatory Person(s) with access to the Subnode (can Y - account. repeated to

specify multiple

signatories). Note that the

node t_person is

of type

t_person_my_cl

ient

is_primary Identifies the primary fixed = 1 N account holder. Only one

signatory may be marked as is_primary. Has to be ‘true’

when node is set.

t_person Subnode holding detailed type Y See 4.5 Type information about the t_person_my_cl t_person_my_client signatory. Mandatory for ient

signatories in the XML

report.

role Subnode holding type N See 5.15 Type enumeration about the role “account_perso account_person_role_type

of current signatory with the n_role_type”

(New in Schema

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balance The account balance after Decimal Y 5000.50

the transaction was conducted.

date_balance N A date to specify the date of Date

the reported balance. (New in Schema Application will show

4.5) balance history

status_code Account status when Enumeration Y See 5.4 Account status type transaction was initiated Ultimate beneficiary of the 100 beneficiary Y Ella Machera

account

beneficiary_comm Any special remark on the 255 N ent beneficiary comments N Generic comments elements 4000

4.5)

opened Y 2003-01-25T00:00:00 Date account opened DateTime closed N 2006-03-25T00:00:00 Date account closed DateTime

Table 10: Details type "t_account_my_client"

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4.2 Type t_account

Figure 10: Overview type" t_account"

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Name Description Length Req. Example

Institution_name Bank of … The name of the Bank 255 Y

(New in Schema 3.0) institution_code 50 Y - Institution code issued by

FIU (one

swift SWIFT code according to 11 of ATTBVI them) ISO 9362 Non_banking_inst N Investment company A flag to cover cases where Boolean

itution the account belongs to non-

(New is Schema 3.0) banking institution Branch 255 N ABX12 Branch code or name

(Increased to 255

chars in Schema 3.1) Account Account number 50 Y 31032027088

(Increased to 50 chars

in Schema 3.1)

currency_code Currency the account is kept Enumeration N See 5.13 Currencies

in

account_name This is a free text field used 255 Y Private savings account

(Increased to 255 to “Label” the account; for example a saving book chars in Schema 3.1)

account with anonymous owner, or an Entity account

dedicated to Invoices, etc. iban 34 N IBAN LT601010012345678901 client_number 30 N 31032027088 Client number personal_account_ Enumeration N See 5.3 Account type Account Type type

t_entity Business entity owning the type N See 4.4 Type t_entity t_entity account

signatory Person(s) with access to the Subnode (can N - account. be repeated to specify

multiple

signatories).

Note that the

node

t_person is of

type t_person

is_primary Identifies the primary fixed = 1 N account holder. Only one

signatory may be marked as

is_primary. Has to be ‘true’ when node is set.

t_person Subnode holding detailed type Y See 4.6 Type t_person information about the t_person signatory. Mandatory for

signatories in the XML

report.

role Subnode holding type N See 5.15 Type enumeration about the role “account_pers account_person_role_type

of current signatory with the on_role_type” (New in Schema

account. report. 4.5)

closed DateTime N 2006-03-25T00:00:00 Date account closed

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balance Decimal N 5000.50 The account balance after

the transaction was

conducted.

date_balance A date field to specify the Date N

date of the reported balance. (New in Schema Application will show

4.5) balance history

status_code Account status when Enumeration N See 5.4 Account status type transaction was initiated

beneficiary Ultimate beneficiary of the 100 N Ella Machera

account

beneficiary_comm Any special remark on the 255 N ent beneficiary comments N Generic comments elements 4000 (New in Schema

4.5)

Table 11: Details type "t_account"

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4.3 Type t_entity_my_client

The structure of this type is similar to that of type t_entity, with some added restrictions i.e. some nodes which are not mandatory in t_entity may be mandatory in t_entity_my_client These restrictions are defined by the local FIU.

Figure 11: Overview type "t_entity_my_client"

Name Description Length Req. Example Name Name of Entity 255 Y DoeComp

Commercial_name The “traded as” name of 255 N the entity Incorporation_legal_form The legal form of the Type Y See 5.11 Entity Legal Form (New in Schema 3.0) entity “legal_form_ Type type” The registration number of fincorporation_number the entity/ “company” in 50 Y -

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the relevant authority (e.g. Chamber of Commerce)

(Extended to 50 chars) Business Business area of the entity 255 Y Free text describing business e.g. IT Services,Import s, Export etc. Phones A Holder node for a Y (New in Schema 3.0) 1..many Phones Phone One occurrence of phone Type Y See 4.9 Type node “t_phone” t_phone Addresses A Holder node for a Y (New in Schema 3.0) 1..many Addresses Address One occurrence of Type Y 4.8 Type address node “t_address” t_address Email Email address email_address N [email protected] (New in Schema 3.1) (255) url Entity web address 255 N www.entity.com

incorporation_state Name of the State 255 Y - incorporation_country_co Country Enumeration Y See 5.14 de Country Codes director_id Individuals related to the type Y See 4.5 Type legal person (Business t_person_my t_person_my_cl This node has in 4.5 a new Entity). _client ient element “role” to describe (Subnode can the relationship of the be repeated individual to the entity for multiple entity_person_role_type persons) incorporation_date Incorporation registration Date Y (New in schema 4.5) date business_closed Boolean to indicate if the Boolean N (New in schema 4.5) company is closed down date_business_closed If entity is closed then Date N (New in schema 4.5) specify close date if any. tax_number The entity tax number 100 N (New in schema 4.5) tax_registration_number Registration number of 100 N (New in schema 4.5) the entity by the Tax auth. Comments Generic comments field 4000 N (New in schema 4.5) Table 12: Details type "t_entity_my_client"

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4.4 Type t_entity

Figure 12: Overview type "t_entity"

Name Description Length Req. Example Name Name of Entity 255 Y DoeComp

Commercial_name The “traded as” name of 255 N the entity See 5.11 Entity Incorporation_legal_form The legal form of the Type N Legal Form Type (New in Schema 3.0) entity “legal_form_ type” incorporation_number the registration number of 50 N - the entity/"company" in (Extended to 50 chars) the relevant authority (e.g. Chamber of Commerce) Business Business area of the entity 255 N Text describing business e.g. IT

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Services,Imp, Exp etc. Phones A Holder node for a N (New in Schema 3.0) 1..many Phones Phone One occurrence of phone Type N See 4.9 Type node “t_phone” t_phone Addresses A Holder node for a N (New in Schema 3.0) 1..many Addresses Address One occurrence of Type N See 4.8 Type address node “t_address” t_address

Email Email address email_address N [email protected] (New in Schema 3.1) (255) url Entity web address 255 N www.entity.co m

incorporation_state Name of the State 255 N - incorporation_country_code Country Enumeration N See 5.14 Country Codes director_id Individuals authorized type t_person N See 4.6 Type t_person This node has in 4.5 a new optional element “role” to describe the role of the subject in the entity from type entity_person_role_type incorporation_date Incorporation registration Date N (New in Schema 4.5) date business_closed Boolean to indicate if the Boolean N (New in Schema 4.5) company is closed down date_business_closed If entity is closed then Date N specify close date if (New in Schema 4.5) available tax_number The entity tax number 100 N (New in Schema 4.5) tax_registration_number The registration number 100 N (New in Schema 4.5) of the entity by the Tax authorities comments Generic comments field 4000 N (New in Schema 4.5)

Table 13: Details type "t_entity"

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Type t_person_my_client 4.5 The structure of this type is similar to that of type t_person, with some added restrictions i.e. some nodes which are not mandatory in t_person may be mandatory in t_person_my_client These restrictions are defined by the local FIU

Figure 13: Overview type "t_person_my_client"

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Name Description Length Req. Example gender Gender Enumerati Y M or F on Title Title 30 Y Dr. first_name First name 100 Y Elyas middle_name Middle name 100 N X. prefix Prefix name 100 N Van, Von,… last_name Last name 100 Y Machera Reporting entity should submit birthdates for persons who are their customers. birthdate Birth date DateTime Y 1953-01- 25T00:00:00 Birth_place Place of birth 255 N Vienna (New in Schema 3.0) mothers_name Can be used as father, 100 N Smith mother, second name, Other name, etc. as per country’s regulation Alias Alias Name, Known 100 N as, ..etc SSN Please provide NIN 25 Y Biometric in place of SSN if (New in Schema 3.0) available. Verified Number which uniquely identify a person passport_number No. of passport 25 N Passport num to (New in Schema 4.5) be used as unification rule passport_country Passport issue country 25 N Passport country (New in Schema 4.5) (Can be reported only to be used as when there is a unification rule passport number) Any additional identification number id_ number rather than Passport. 25 N Additional (New in Schema 4.5) identification number

Phones A Holder node for a Y (New in Schema 3.0) 1..many Phones Phone One occurrence of Type Y See 4.9 Type phone node “t_phone” t_phone Addresses A Holder node for a Y (New in Schema 3.0) 1..many Addresses Address One occurrence of Type Y See 4.8 Type address node t_address t_address

Nationality1 Country of Enumeration Y See 5.14 Country Nationality (1) Codes Nationality2 Country of Enumeration N See 5.14 Country (New in Schema 3.0) Nationality (2) Codes

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Nationality3 Country of Enumeration N See 5.14 Country (New in Schema 3.0) Nationality (3) Codes residence Country of residence Enumeration Y See 5.14 Country Codes Email Email address Type N [email protected] (Enlarged in Schema 3.1 to 255 email_addre chars) ss (255) Occupation Occupation 255 Y Financial Analyst (enlarged in 3.1)

employer_name Employer’s name 255 N FIU (enlarged in 3.1) employer_address_id Employer’s address type N 4.8 Type t_address t_address employer_phone_id Employer’s phone type N See 4.9 Type t_phone t_phone identification Subnode(s) for type Y See 4.11 Type identification t_person_id t_person_identifi documents entification cation (This subnode can be repeated to specify multiple identificatio n documents) deceased A Boolean to Boolean N (New in schema 4.5) indicated if person has passed away deceased_date If deceased, then RE Date N

(New in schema 4.5) can report deceased date if known as well tax_number The person tax 100 N (New in schema 4.5) number tax_reg_number The person tax reg. 100 N (New in schema 4.5) number by tax auth. source_of_wealth Free text description 255 Y (New in schema 4.5) of the person source of wealth comments Generic comments 4000 N (New in schema 4.5) field Table 14: Details "type t_person_my_client"

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4.6 Type t_person

Figure 14: Overview type "t_person"

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Name Description Length Req. Example gender Gender Enumerati Y M or F on Title Title 30 N Dr. first_name First name 100 Y Elyas middle_name Middle name 100 N X. prefix Prefix name 100 N Van, Von,… last_name Last name 100 Y Machera birthdate Birth date DateTime N 1953-01- 25T00:00:00

Birth_place Place of birth 255 N Vienna (New in Schema 3.0) mothers_name Can be used as father, 100 N Smith mother, second name, Other name, etc. as per country’s regulation alias Alias, Known As, ..etc 100 N

SSN Please provide NIN 25 N National ID in place of SSN if (New in Schema 3.0) available. number which uniquely identify a person passport_number No. of passport 25 N Passport num to (New in Schema 4.5) be used as unification rule passport_country Passport issue country 25 N Passport country (New in Schema 4.5) (Can be reported only to be used as when there is a unification rule passport number) id_ number Any additional 25 N Additional (New in Schema 4.5) identification number identification rather then NIN and number passport Phones A Holder node for a N (New in Schema 3.0) 1..many Phones Phone One occurrence of Type N See 4.9 Type phone node “t_phone” t_phone Addresses A Holder node for a N (New in Schema 3.0) 1..many Addresses Address One occurrence of Type N 4.8 Type address node t_address t_address

Nationality1 Country of Enumeration N See 5.14 Country Nationality (1) Codes Nationality2 Country of Enumeration N See 5.14 Country (New in Schema 3.0) Nationality (2) Codes Nationality3 Country of Enumeration N See 5.14 Country (New in Schema 3.0) Nationality (3) Codes residence Country of residence Enumeration N See 5.14 Country Codes

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Email Email address 255 N [email protected]

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(Enlarged in Schema 3.1 to 255 chars) Occupation Occupation 255 N Financial Analyst (enlarged in 3.1 to 255) employer_name Employer’s name 255 N FIU (enlarged in 3.1 to 255) employer_address_id Employer’s address type N See 4.8 Type t_address t_address employer_phone_id Employer’s phone type N See 4.9 Type t_phone t_phone identification Subnode(s) for type N See 4.11 Type identification t_person_id t_person_identifi documents entification cation (This subnode can be repeated to specify multiple identificatio n documents) deceased A Boolean to Boolean N (New in schema 4.5) indicated if person has passed away deceased_date If deceased, then RE Date N (New in schema 4.5) can report deceased date if known as well tax_number The person tax 100 N (New in schema 4.5) number tax_reg_number The person tax reg. 100 N (New in schema 4.5) number by tax auth. source_of_wealth Free text description 255 N (New in schema 4.5) of the person source of wealth comments Generic comments 4000 N (New in schema 4.5) field Table 15: Details type "t_person"

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4.7 Type t_party

Figure 15: Overview type "t_party"

Name Description Length Req. Example role Subject role in Enumeration Y Buyer, Seller,.. the transaction Subject: One occurrence of the supported subject types must be included. Person Involved Person Type “t_person” Y See 4.6 Type t_person Person_my_client Involved Person Type Y See 4.5 Type “t_person_my_client” t_person_my_cl ient account Involved Type “t_account” Y See 4.2 Type Account t_account account_my_client Involved Type “t_ Y See 4.1 Type Account account_my_client” t_account_my_ client entity Involved Entity Type “t_ entity” Y See 4.4 Type t_entity entity_my_client Involved Entity Type “t_ Y entity_my_client”

funds_code Type of funds Enumeration N See 5.2 Funds used in type initiating Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 39 of 82

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transaction funds_comment Description, if 255 N - funds_code is “O” (Other). foreign_currency If the type N See 4.10 Type transaction is t_foreign_currency t_foreign_curre conducted in ncy foreign currency, then specify the foreign currency details. country Country of the Enumeration Y See 5.14 transaction Country Codes significance The Integer N 0-10 (New in schema 4.5) significance of the subject in the transaction comments Generic 4000 N (New in schema 4.5) comments Table 16: Details type "t_party"

4.8 Type t_address

Figure 16: Overview type" t_address"

Name Description Length Req. Example Address_type The contact type of the Enumeration Y Private, (New in Schema 3.0) address Business,.. See 5.9 Contact Type Address Street name and house 100 Y - Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 40 of 82

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number Town Name of 255 N Town/district/.. as part of a City City City 255 Y -

Zip Zip Code 10 N A-1220

country_code Country Enumeration Y See 5.14 Country Codes State State 255 N

comments Generic comments 4000 N (New in schema 4.5) Table 17: Details type "t_address"

4.9 Type t_phone

Figure 17: Overview type "t_phone"

Name Description Length Req. Example tph_contact_type The contact type Enumeration Y Private, (New in Schema 3.0) of the Phone Business,.. See 5.9 Contact Type tph_communication_type The comm.. type (New in Schema 3.0) of the Phone Enumeration Y Landline, mobile ,fax,.. See 5.10 Communication Type tph_country_prefix Country phone 4 N 0043 code tph_number Phone number 50 Y 6655778 tph_extension Phone’s extension 10 N 7789 comments Generic 4000 N (New in schema 4.5) comments Table 18: Details type "t_phone" Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 41 of 82

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4.10 Type t_foreign_currency

Figure 18: Overview type" t_foreign_currency"

Name Description Length Req. Example foreign_currency_code Currency Code Enumeration Y See 5.13 according to ISO Currencies 4217 foreign_amount Transaction amount Decimal Y 1300.50 in foreign currency foreign_exchange_rate Exchange rate Decimal Y 1.45 which has been used for transaction Table 19: Details type "t_foreign_currency"

4.11 Type t_person_identification

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Figure 19: Overview type "t_person_identification"

Name Description Length Req. Example type Document type Enumeration Y See 5.5 Identifier type number ID of the identification 255 Y AT08154711 document issue_date Identification document issue DateTime N 2001-12- date 17T09:30:47 expiry_date Identification document DateTime N 2012-01- expiry date 01T00:00:00 issued_by Name of Authority issued the 255 N Interior New in Schema 3.1 document Ministry issue_country Country where the document Enumeration Y See 5.14 was issued Country Codes comments Generic comments field 4000 N

Table 20: Type "t_person_identification"

4.12 Type report_party_type New type in schema 4.5. Represents an involved subject in a report and its details. Subject can be a Person, an Account or an Entity – one of them can be included per involved party.

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Figure 20: Overview type "report_party_type"

Name Description Length Req. Example One of the following subject nodes must be included when activity node is used See 4.6 person Represents an involved t_person type Y t_person person node See 4.2 account Represents an involved t_account Y t_account account type See 4.4 entity Represents an involved entity t_entity type Y t_entity

significance The significance of the Integer Y 0 - 10 subject in the report reason Why the subject is involved 4000 Y in the current report comments Generic comments element 4000 N

Table 21: Type "report_party_type"

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5. Lookup Values

As per schema 4.5, all schema lookups are defined as enumerations. goAML application will introduce an option to update the schema automatically with the lookup codes defined by the FIU in the “Lookup Master” screen. Reporting entities will not be able anymore to submit reports with undefined lookup codes.

Most of the lookup enumerations mentioned below are just predefined suggestions. Feel free to adjust them using “Lookup Master” screen.

5.1 Submission type – goAML Enumeration

Item Description E Electronically M Manually Table 22: Submission type

Funds type 5.2 * The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application.

Value Description A Deposit B Electronic funds transfer C Currency exchange DW Divine Warrant E Bank draft F Money order G Traveler’s cheques H Life insurance policy J Securities K Cash L From Account MM Money Market Instrument P Cheque Table 23: Funds type

Account type 5.3 *The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application.

Item Description C Call Deposit D Current Business E Current Personal P Domicilliary Account Y Escrow Account O Export Proceeds Dormicilliary Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 45 of 82

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I Fixed Deposit T Internal Account A Savings L Trading Account U Transit/Remittance Account B Trust Account Table 24: Account type

Account status type 5.4 *The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application Item Description A Active CL Closed C Dormant h Fully Blocked B Partially Blocked (PND) Table 25: Account status type

Identifier type 5.5 *The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application. Item Description N Agent Identification A Driver's license B National Identity Card C Passport R RC No O Third Party ID E Voter Registration Card Table 26: Identifier type

5.6 Conduction Type *The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application Item Description B ATM k Cash T Courier C Electronic transaction A In-branch/Office E Payable Instruments Table 27: Conduction Type

Transaction Item Status 5.7 *the following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application. Item Description A Bought B Sold Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 46 of 82

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C Let CF Confiscated/Forfeited D Hired E Exchanged F Donated G Destroyed H Other I Inherited Table 28: Transaction Item Status

5.8 Report Code – goAML Enumeration

Item Description AIF Additional Information File CTR Currency Transaction Reports EFT Electronic/Express Funds Transfer(EFT) IFT International Funds Transfer M Manual SAR Suspicious Activity Report STR Suspicious Transaction Report SUTR S-UTR (Suspicious UTR) UTR Unusual Transaction Report Table 29: Report Code

5.9 Contact Type *The following list is a suggestion. Item Description B Business P Private O Operational R Registered Table 30: Contact type

Communication Type 5.10 *the following list is a suggestion. Actual codes defined by FIU in Lookup Master will be added automatically to the Schema by goAML client application.

Item Description E Email F Fax L Landline Phone M Mobile Phone O Others P Pager S Satellite Phone Table 31: Communication Type

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Entity Legal Form Type 5.11 * The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application.

Item Description A Limited Liability Company G Ordinary Business Registration B Public Liability Company R Registered Table 32: Legal Form Type

Transaction Item Type 5.12 * The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application.

Item Description B Bond CH Chemicals C Commodity E Equipment F Furniture G Goods J Jewelry M Machines O Others PM Precious Metal P Property S Services Sh Shares V Vehicle W Weapon Table 33: Transaction Item Type

5.13 Currencies - Enumeration World Currencies (and their abbreviations) listed by ISO 4217

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Table 34: Currency Codes

Value Description - UNKNOWN ADF Andorran franc (1:1 peg to the French franc) ADP Andorran Peseta AED United Arab Emirates Dirham AFA Afghani AFN Afghan afghani ALL Lek AMD Dram ANG Netherlands Antilles Guilder AOA Angolan kwanza AOK Kwanza AON New Kwanza AOR Angolan kwanza readjustado ARA Austral ARL Argentine peso ley ARP Argentinean Peso ARS Argentinean Nuevo Peso ATS Schilling (no longer in use) AUD Australian Dollar AWG Aruban Guilder AZM Azerbaijani Manat AZN Azerbaijani manat BAM Convertible Mark BBD Barbados Dollar BDT Taka BEC Convertible Belgian Franc (no longer in use) BEF Belgian Franc (also known as Frank - no longer in use) BEL Financial Belgian Franc (no longer in use) BGL Lev BGN Bulgarian lev BHD Bahraini Dinar BIF Burundi Franc BMD Bermudian Dollar BND Brunei Dollar BOB Boliviano BOP Bolivian Peso BOV Bolivian Mvdol (funds code) BRB Brazilian cruzeiro novo BRC Cruzeiro BRE Brazilian cruzeiro BRL Real BRN Brazilian cruzado novo BRR Cruzeiro Real BSD Bahamian Dollar BTN Ngultrum Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 49 of 82

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Value Description BUK Replaced by MMK BWP Pula BYR Belarussian Rouble BZD Belize Dollar CAD Canadian Dollar CDF Congolese franc CDZ New Zaïre CHE WIR Bank (complementary currency) CHF Swiss Franc CHW WIR Bank (complementary currency) CLF Unidades de Fomento CLP Chilean Peso CNY Yuan Renminbi COP Colombian Peso COU Unidad de Valor Real CRC Costa Rican Colón CSD Serbian Dinar CSK Koruna of former Czechoslovakia. CUC Cuban convertible peso CUP Cuban Peso CVE Escudo Caboverdiano CYP Cypriot Pound CZK Czech Koruna DDM Former East German Mark, DEM subsequently in use DEM Deutsche Mark (no longer in use) DJF Djibouti Franc DKK Danish Krone DOP Dominican Republic Peso DZD Algerian Dinar ECS Sucre (no longer in use) ECV Ecuador Unidad de Valor Constante (funds code) (discontinued) EEK Kroon EGP Egyptian Pound ERN Eritrean Nakfa ESA Spanish Peseta, Account A (no longer in use) ESB Spanish Peseta, Account B (no longer in use) ESP Spanish Peseta (no longer in use) ETB Ethiopian Birr EUR Euro (replacement name for the ECU) FIM Markka (no longer in use) FJD Fiji Dollar FKP Falkland Pound FRF French Franc (no longer in use) GBP Pound Sterling (United Kingdom Pound) GEL Lari GHC Cedi

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Value Description GHS Ghanaian cedi GIP Gibraltar Pound GMD Dalasi GNE Guinean syli GNF Guinean franc GNS Syli (also known as Guinea Franc) GQE Ekwele GRD Greek Drachma (no longer in use) GTQ Quetzal GWP Guinea-Bissau Peso GYD Guyana Dollar HKD Hong Kong Dollar HNL Lempira HRD Croatian Dinar HRK Croatian Kuna HTG Gourde HUF Forint IDR Rupiah IEP Punt (no longer in use) ILP Israeli lira ILR Israeli shekel ILS Shekel INR Indian Rupee IQD Iraqi Dinar IRR Iranian Rial ISJ Icelandic old krona ISK Icelandic Króna ITL Italian Lira (no longer in use) JMD Jamaican Dollar JOD Jordanian Dinar JPY Yen KES Kenyan Shilling KGS Kyrgyzstani Som KHR Riel KMF Comorian Franc KPW Democratic People's Republic of Korean Won KRW Republic of Korean Won KWD Kuwaiti Dinar KYD Cayman Islands Dollar KZT Tenge LAJ Lao kip LAK Kip LBP Lebanese Pound LKR Sri Lankan Rupee LRD Liberian Dollar LSL Loti

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Value Description LSM Maloti LTL Litas LUF Luxembourg Franc (no longer in use) LVL Lats LYD Libyan Dinar MAD Moroccan Dirham MAF Moroccan franc MCF Monegasque franc (currency union with FRF) MDL Moldavian Leu MGA Malagasy ariary MGF Malagasy Franc MKD Macedonian Dinar MKN Old Macedonian denar A/93 MLF Malian Franc MMK Kyat MNT Tugrik MOP Pataca MRO Ouguiya MTL Maltese Lira MTP Maltese Pound, replaced by Maltese Lira MUR Mauritius Rupee MVQ Maldive rupee MVR Rufiyaa MWK Malawian Kwacha MXN Mexican New Peso (replacement for Mexican Peso) MXP Mexican Peso, replaced by Mexican New Peso MXV Mexican Unidad de Inversion (UDI) (funds code) MYR Ringgit (also known as Malaysian Dollar) MZM Metical MZN Mozambican metical NAD Namibian Dollar NFD Newfoundland dollar NGN Naira NIC Córdoba NIO Cordoba oro NLG Dutch Guilder (no longer in use) NOK Norwegian Krone NPR Nepalese Rupee NZD New Zealand Dollar OMR Omani Rial PAB Balboa PEH Peruvian sol PEI Inti PEN New Sol PES Sol (replaced by New Sol [PEN]) PGK Kina

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Value Description PHP Philippines Peso PKR Pakistani Rupee PLN New Zloty PLZ Zloty (replaced by New Zloty [PLN]) PTE Portuguese Escudo (no longer in use) PYG Guarani QAR Qatari Riyal ROL Romanian Leu RON Romanian new leu RSD Serbian dinar RUB Russian Federation Rouble (formerly RUR) RUR Russian rouble A/97 RWF Rwandan Franc SAR Saudi Riyal SBD Solomon Islands Dollar SCR Seychelles Rupee SDD Sudanese Dinar SDG Sudanese pound SDP Sudanese Pound SEK Swedish Krona SGD Singapore Dollar SHP St Helena Pound SIT Tolar SKK Slovak Koruna SLL Leone SML San Marinese lira (currency union with ITL and VAL) SOS Somali Shilling SRD Surinamese dollar SRG Surinam Guilder SSP South Sudanese Pound STD Dobra SUR Union of Soviet Socialist Republics Rouble SVC El Salvadorian Colón SYP Syrian Pound SZL Lilangeni THB Baht TJR Tajik Rouble TJS Tajikistani somoni TMM Turkmenistani Manat TMT Turkmenistani manat TND Tunisian Dinar TOP Pa'anga TPE Timorian Escudo TRL Turkish Lira TRY Turkish lira TTD Trinidad and Tobago Dollar

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Value Description TWD Taiwan Dollar TZS Tanzanian Shilling UAH Hryvna UAK Karbovanet UGS Ugandan Shilling UGX Ugandan shilling UKP Incorrectly used for GBP USD United States Dollar USN United States Dollar (Next day) USS United States Dollar (Same day) UYN Uruguay old peso UYP Uruguayan Peso, replaced by Uruguayan New Peso (UYU) UYU Uruguayan New Peso UZS Uzbekistani Som VAL Vatican lira (currency union with ITL and SML) VEB Bolivar VEF Venezuelan bolívar fuerte VES Bolívar Soberano VND Viet Nam Dông VUV Vatu WST Tala XAF Franc de la Communauté financière africaine XAG Silver (one troy ounce) XAU Gold XBA European Composite Unit XBB European Monetary Unit XBC European Unit of Account 9 XBD European Unit of Account 17 XCD East Caribbean Dollar XDR International Monetary Fund Special Drawing Rights XEU ECU (not an official currency, replaced by the Euro) XFO Gold franc (special settlement currency) XFU UIC franc (special settlement currency) XOF West African Franc XPD Palladium (one troy ounce) XPF Franc des Comptoirs français du Pacifique XPT Platinum (one troy ounce) XTS Code reserved for testing purposes XXX No currency YDD South Yemeni Dinar YER Yemeni Riyal YUD Yugoslavian New Dinar (no longer in use) YUG Yugoslav dinar YUM Yugoslav dinar YUN Yugoslav dinar YUO Yugoslav dinar

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Value Description YUR Yugoslav dinar ZAL Rand (financial) ZAR Rand ZMK Zambian Kwacha (obsolete) ZMW Zambian Kwacha ZRN Zaïrean new zaïre ZRZ Replaced by CDZ ZWC Rhodesian dollar ZWD Zimbabwe Dollar ZWL Zimbabwe dollar ZWN Zimbabwean dollar A/08 ZWR Zimbabwean dollar A/09

Country Codes - Enumeration 5.14 This list states the country names (official short names in English) in alphabetical order as given in ISO 3166-1 and the corresponding ISO 3166-1-alpha-2 code elements. Value Description - UNKNOWN AC Ascension Island AD ANDORRA AE UNITED ARAB EMIRATES AF AFGHANISTAN AG ANTIGUA AND BARBUDA AI ANGUILLA AL ALBANIA AM ARMENIA AN NETHERLANDS ANTILLES AO ANGOLA AP African Regional Industrial Property Organization AQ ANTARCTICA AR ARGENTINA AS AMERICAN SAMOA AT AUSTRIA AU AUSTRALIA AW ARUBA AX ÅLAND ISLANDS AZ AZERBAIJAN BA BOSNIA AND HERZEGOVINA BB BARBADOS BD BANGLADESH BE BELGIUM BF BURKINA FASO BG BULGARIA BH BAHRAIN BI BURUNDI BJ BENIN Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 55 of 82

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Value Description BL SAINT BARTHÉLEMY BM BERMUDA BN BRUNEI DARUSSALAM BO BOLIVIA BQ Bonaire, Saint Eustatius and Saba BR BRAZIL BS BAHAMAS BT BHUTAN BU Burma BV BOUVET ISLAND BW BOTSWANA BX Benelux Trademarks and Designs Office BY BELARUS BZ BELIZE CA CANADA CC COCOS (KEELING) ISLANDS CD CONGO, THE DEMOCRATIC REPUBLIC OF THE CF CENTRAL AFRICAN REPUBLIC CG CONGO CH SWITZERLAND CI COTE D'IVOIRE CK COOK ISLANDS CL CHILE CM CAMEROON CN CHINA CO COLOMBIA CP Clipperton Island CR COSTA RICA CS SERBIA AND MONTENEGRO CU CUBA CV CAPE VERDE CW Curaçao CX CHRISTMAS ISLAND CY CYPRUS CZ CZECH REPUBLIC DE GERMANY DG Diego Garcia DJ DJIBOUTI DK DENMARK DM DOMINICA DO DOMINICAN REPUBLIC DY BENIN DZ ALGERIA EA Ceuta, Melilla EC ECUADOR EE ESTONIA

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Value Description EF Union of Countries under the European Community Patent Convention EG EGYPT EH WESTERN SAHARA EM European Trademark Office EP European Patent Organization ER ERITREA ES SPAIN ET ETHIOPIA EU European Union EV Eurasian Patent Organization EW ESTONIA FI FINLAND FJ FIJI FK FALKLAND ISLANDS (MALVINAS) FL Liechtenstein FM MICRONESIA, FEDERATED STATES OF FO FAROE ISLANDS FR FRANCE FX France, Metropolitan GA GABON GB UNITED KINGDOM GC Patent Office of the Cooperation Council for the Arab States of the Gulf (GCC) GD GRENADA GE GEORGIA GF FRENCH GUIANA GG GUERNSEY GH GHANA GI GIBRALTAR GL GREENLAND GM GAMBIA GN GUINEA GP GUADELOUPE GQ EQUATORIAL GUINEA GR GREECE GS SOUTH GEORGIA AND THE SOUTH SANDWICH ISLANDS GT GUATEMALA GU GUAM GW GUINEA-BISSAU GY GUYANA HK HONG KONG HM HEARD ISLAND AND MCDONALD ISLANDS HN HONDURAS HR CROATIA HT HAITI HU HUNGARY IB International Bureau of WIPO

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Value Description IC Canary Islands ID INDONESIA IE IRELAND IL ISRAEL IM ISLE OF MAN IN INDIA IO BRITISH INDIAN OCEAN TERRITORY IQ IRAQ IR IRAN, ISLAMIC REPUBLIC OF IS ICELAND IT ITALY JA Jamaica JE JERSEY JM JAMAICA JO JORDAN JP JAPAN KE KENYA KG KYRGYZSTAN KH CAMBODIA KI KIRIBATI KM COMOROS KN SAINT KITTS AND NEVIS KP KOREA, DEMOCRATIC PEOPLE'S REPUBLIC OF KR KOREA, REPUBLIC OF KS KOSOVO (Old - KS) KW KUWAIT KY CAYMAN ISLANDS KZ KAZAKHSTAN LA LAO PEOPLE'S DEMOCRATIC REPUBLIC LB LEBANON LC SAINT LUCIA LF Libya Fezzan LI LIECHTENSTEIN LK SRI LANKA LR LIBERIA LS LESOTHO LT LITHUANIA LU LUXEMBOURG LV LATVIA LY LIBYAN ARAB JAMAHIRIYA MA MOROCCO MC MONACO MD MOLDOVA, REPUBLIC OF ME Montenegro MF SAINT MARTIN (FRENCH PART) MG MADAGASCAR

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Value Description MH MARSHALL ISLANDS MK MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF ML MALI MM MYANMAR MN MONGOLIA MO MACAO MP NORTHERN MARIANA ISLANDS MQ MARTINIQUE MR MAURITANIA MS MONTSERRAT MT MALTA MU MAURITIUS MV MALDIVES MW MALAWI MX MEXICO MY MALAYSIA MZ MOZAMBIQUE NA NAMIBIA NC NEW CALEDONIA NE NIGER NF NORFOLK ISLAND NG NIGERIA NI NICARAGUA NL NETHERLANDS NO NORWAY NP NEPAL NR NAURU NT Neutral Zone NU NIUE NZ NEW ZEALAND OA African Intellectual Property Organization OM OMAN PA PANAMA PE PERU PF FRENCH POLYNESIA PG PAPUA NEW GUINEA PH PHILIPPINES PI PHILIPPINES PK PAKISTAN PL POLAND PM SAINT PIERRE AND MIQUELON PN PITCAIRN PR PUERTO RICO PS PALESTINIAN TERRITORY, OCCUPIED PT PORTUGAL PW PALAU

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Value Description PY PARAGUAY QA QATAR RA ARGENTINA RB Bolivia [cf. Botswana: identical code element] RC CHINA RE REUNION RH HAITI RI INDONESIA RL LEBANON RM MADAGASCAR RN NIGER RO ROMANIA RP PHILIPPINES RS Serbia RU RUSSIAN FEDERATION RW RWANDA SA SAUDI ARABIA SB SOLOMON ISLANDS SC SEYCHELLES SD SUDAN SE SWEDEN SF FINLAND SG SINGAPORE SH SAINT HELENA SI SLOVENIA SJ SVALBARD AND JAN MAYEN SK SLOVAKIA SL SIERRA LEONE SM SAN MARINO SN SENEGAL SO SOMALIA SR SURINAME SS South Sudan ST SAO TOME AND PRINCIPE SU USSR SV EL SALVADOR SX Sint Maarten (Dutch part) SY SYRIAN ARAB REPUBLIC SZ SWAZILAND TA Tristan da Cunha TC TURKS AND CAICOS ISLANDS TD CHAD TF FRENCH SOUTHERN TERRITORIES TG TOGO TH THAILAND TJ TAJIKISTAN

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Value Description TK TOKELAU TL TIMOR-LESTE TM TURKMENISTAN TN TUNISIA TO TONGA TP East Timor TR TURKEY TT TRINIDAD AND TOBAGO TV TUVALU TW TAIWAN, PROVINCE OF CHINA TZ TANZANIA, UNITED REPUBLIC OF UA UKRAINE UG UGANDA UK UNITED KINGDOM UM UNITED STATES MINOR OUTLYING ISLANDS UN United Nations US UNITED STATES UY URUGUAY UZ UZBEKISTAN VA HOLY SEE (VATICAN CITY STATE) VC SAINT VINCENT AND THE GRENADINES VE VENEZUELA VG VIRGIN ISLANDS, BRITISH VI VIRGIN ISLANDS, U.S. VN VIET NAM VU VANUATU WF WALLIS AND FUTUNA WG GRENADA WL SAINT LUCIA WO World Intellectual Property Organization WS SAMOA WV Saint Vincent XK KOSOVO YE YEMEN YT MAYOTTE YU Yugoslavia YV Venezuela ZA SOUTH AFRICA ZM ZAMBIA ZR Zaire ZW ZIMBABWE

Table 35: Country Codes

account_person_role_type 5.15 * The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application. Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 61 of 82

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Item Description A Primary Signatory D Director F Fiduciary Agent N Nominee S Shareholder Si Signatory Table 36: Account_person_role_type

entity_person_role_type 5.16 *The following list is a suggestion. Actual codes defined by FIU in “Lookup Master” will be added automatically to the Schema by goAML client application. Item Description A Director B Shareholder C Signatory F Fiduciary Agent N Nominee P Partners S Sole Proprietor Table 37: Entity_person_role_type

5.17 Party Role type Item Description A Payee / Sender B Beneficiary / Receiver C Conductor XD Dest Party XDE Dest Entity XS Source Party XSE Source Entity Table 38: Party Role type

5.18 Entity type Item Description FIU Financial Intelligence Unit (FIU) I Insurance Brokers REI Reporting Entity SH Stake Holder SUP Supervisory Body Table 39: Entity type

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5.19 indicator_type Item Description THRESHOLDREPORT Default indicator to be used for threshold reports CTR/FTR CILPA1 Purchase of large volumes of recharge cards or open an outlets The funds were mainly used for chips purchase but gaming activities CILPA2 cannot be ascertained Large purchases at locations that process funds transfers, such as big box CILPA3 stores and international wire processors. Customers suddenly using lines of credit or pulling from investments if CILPA4 they have not regularly done so in the past. Transactions displaying financial connections between individuals who CILPA5 have previously raised suspicion. Transactions involving certain high-risk jurisdictions such as locations in the midst of or in proximity to, armed conflict where terrorist groups CILPA6 operate or locations which are subject to weaker ML/TF controls. Client donates to a cause that is subject to derogatory information that is CILPA7 publicly available (e.g. crowdfunding initiative, charity, NPO, NGO, etc.). Suspicious pattern emerges from a client's transactions (e.g. transactions CILPA8 take place at the same time of day). Acquaintances bet against each other in even-money games and it CILPA9 appears that they are intentionally losing to one of the parties. Recent accounts from law enforcement and regulatory authorities allege that certain casino patrons may have conspired with casino personnel to structure transactions to evade reporting and/or recordkeeping CILPA10 requirements. A customer wires funds derived from non-gaming proceeds, to or through a bank and/or a non-bank financial institution(s) located in a country that CILPA11 is not his/her residence or place of business. Constant receipt/making of calls from/to a high-risk jurisdiction that is CILPA12 inherently vulnerable to TF risk. A customer appears to use a casino’s account primarily as a temporary repository for funds by making frequent deposits into the account and, within a short period of time (e.g., one to two days), requests money transfers of all but a token amount to domestic or foreign-based bank CILPA13 accounts. A pair of bettors frequently cover between them both sides of an even bet, such as: - Betting both “red and black” or “odd and even” on roulette; - Betting both with and against the bank in baccarat/mini- baccarat; or - Betting the “pass line” or “come line” and the “don’t pass CILPA14 line” or “don’t come line” in craps; CILPA15 Client makes inquiries that would indicate a desire to avoid reporting. Client conducts transactions with different representatives in an apparent CILPA16 attempt to avoid detection. A customer or a group of individuals forge signatures or use counterfeit CILPA17 business or personal cheques to obtain currency, chips or tokens Client requests for winnings to be paid to a third party in another country CILPA18 (of interest) where the casino has another branch.

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Item Description Client requests the transfer of winnings to the bank account of a third CILPA19 party or a known drug source country, organized crime region, etc. Client requests for winnings to be paid to a third party in another country CILPA20 (terrorism friendly) where the casino has another branch. Client requests a winnings cheque in a third party's name (on a terrorist CILPA21 watch list/designated person). Client requests the transfer of winnings to the bank account of a third CILPA22 party or a known terrorist friendly jurisdiction, etc. Mobile transfers of funds to and from wanted person by CILPA23 national/international law enforcement agency Client requests the transfer of winnings to the bank account of a third party or a known drug source country or to a country where there is no CILPA24 effective anti-money-laundering system. Client enquires about opening an account with the casino and the ability to transfer the funds to other locations when you do not know the client CILPA25 as a regular, frequent or large volume player. A customer spending time without playing games. Client is known to use CILPA26 multiple names. IP address shows funds come in from a known terrorism CILPA27 friendly/designated terrorist jurisdiction. IP address shows funds come in from a third party or a known drug source CILPA28 jurisdiction. A customer routinely bets both sides of the same line for sporting events (i.e. betting both teams to win) and thus the amount of overall loss to the CILPA29 customer is minimal (known as hedging). The use of under aged kids who have no business owning phones should CILPA30 be discouraged Numbers with incomplete documentation should be CILPA31 deregistered/disconnected Customers who try to keep their transactions just below the reporting or CILPA32 recordkeeping thresholds Client requests the transfer of winnings to a third party or a known drug CILPA33 source country CILPA34 Cash transaction Transaction with enormous amount and frequent chips purchase CILPA35 incommensurate with subjects’ background Purchase of chips without gaming activities and the transactions were CILPA36 conducted on behalf of unknown third parties There is no apparent relationship between the originator and the CILPA37 beneficiary of the fund transfers Individuals or companies suspected of being involved, or linked to, International Wildlife Trade networks using bank accounts and addresses CMIA1 located in different countries Securities accounts introduced from one intermediary to another without adequate customer due diligence/know your customer (CDD/KYC) CMIA2 investigations or from high risk jurisdictions

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Item Description CMIA3 The use of front persons or entities (eg corporations, trusts); Dealings with financial institutions and intermediaries or customers CMIA4 operating in jurisdictions with ineffective AML/CFT systems Unregisterred Real Estate Development or unregulated investment CMIA5 vehicles (eg Ponzi Schemes) CMIA6 Fictitious trading schemes The customer opens numerous accounts for different legal entities that CMIA7 the customer controls The customer makes a large purchase or sale of a security, or option on a CMIA8 security, shortly before news is issued that affects the price of the security The customer is known to have friends or family who work at or for the securities issuer; the customer lives in the locality where the issuer is CMIA9 located The customer’s purchase does not correspond to his or her investment profile For example, the customer may never have invested in equity CMIA10 securities, but does so at an opportune time The customer’s profile does not suggest a legitimate business reason for CMIA11 receiving many third-party deposits; and CMIA12 Changing share ownership in order to transfer wealth across borders The customer’s account is opened or significantly funded shortly before a CMIA13 purchase The customer sells his or her position in a security in conjunction with a CMIA14 significant announcement about the security The customer engages in large or repeated trading in securities that are CMIA15 illiquid, low priced or difficult to price The officers or insiders of the issuing company have a history of regulatory violations; the issuing company has failed to make required Estate CMIA16 Development regulatory disclosures CMIA17 The issuing company has been the subject of a prior trading suspension One party purchases securities at a high price and then sells them at a CMIA18 considerable loss A customer engages in prearranged or other non-competitive securities CMIA19 trading, including wash or cross trades of illiquid or low priced securities Wire transfers or payments are made to or from unrelated third parties (foreign or domestic) or where the name or account number of the CMIA20 beneficiary or remitter has not been supplied Many small, incoming wire transfers are made, either by the customer or third parties that are almost immediately withdrawn or Real Estate Development out in a manner inconsistent with customer’s business or CMIA21 history Real Estate Development teeming a long-term investment within a short CMIA22 period CMIA23 Opening multiple accounts or nominee accounts Engaging in boiler room operations ie people marketing others to buy shares of companies without full knowledge of the company’s standings in CMIA24 the market

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Item Description During the account opening process, the person opening the account refuses to provide information to complete CDD/KYC (eg occupation, prior financial relationships, etc), in particular with respect to beneficial CMIA25 ownership The customer deposits a large number of bearer securities at the securities firm and quickly Real Estate Development the securities or sells CMIA26 them in the open marketplace The customer refuses to identify a legitimate source for the funds or provides the securities firm with information that is false, misleading, or CMIA27 substantially incorrect The customer has accounts primarily used for deposits and other accounts CMIA28 primarily used for outgoing payments Deposits in public officials’ accounts with cheques issued by construction companies, individuals or non-governmental entities that previously FGAD1 benefited from public works contracts. Public officials receive loan guarantees from a public corporation or FGAD2 government body, or a loan under favorable conditions. Public officials receive large amounts of money for their attendance in workshops, conferences or as consultants to projects, in order to disguise FGAD3 the origin of the funds from being seen as a payment of corruption. Public officials receive debt forgiveness or repayment requirements are FGAD4 waived by the creditor. Public officials perform transactions with sovereign wealth funds or FGAD5 government-linked companies. Misrepresentation and/or inconsistency between the declared source of wealth of public officials through their sworn asset declarations, and FGAD6 those established during the due diligence process. The immediate transfer of funds from a private entity’s account to a personal account of a public official and the subsequent movement of the FGAD7 funds to third party accounts. Transaction payments of unusual amounts or frequency from public FGAD8 officials to lawyers, accountants, or other professional intermediaries The stated source of wealth of funds received to an account of a public official may be inconsistent with the client's stated career history, FGAD9 expertise, or age. Customer, especially when it is a public official, transferring funds to/from FGAD10 other public officials, including law enforcement officers. Open source information, which can relate specific financial activity to FGAD11 ongoing investigations into individuals, and concerns about corruption. cheques or deposits in favor of public officials and come from accounts of persons that benefited from public procurements/funds, without an FGAD12 evident justification. Payments made by contractors for consultancy services, particularly in industries with a higher risk to corruption, such as arms, mineral extraction, telecoms, public infrastructures, where the amount paid FGAD13 appears to be outside the normal price range for consultancy services. FGAD14 Payments from accounts of MDAs to newly incorporated companies Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 66 of 82

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Item Description Payments from a single government entity to companies that share FGAD15 similar addresses and directors Payments from accounts of MDAs to companies for procurements at the FGAD16 end of the year Payments from accounts of MDAs to individuals/entities around the FGAD17 period of elections Frequent payments to accounts of public officials for purposes of FGAD18 conferences, sitting allowances and Duty Tour Allowances. FGAD19 Companies receiving funds from MDAs for unrelated business activities Accounts with incomplete KYC receiving huge inflows from accounts of FGAD20 MDAs Public Official making payments/donations to NPOs/Charities known or associated, or suspected to be linked to terrorism or based in countries FGAD21 reputed to be state sponsors of terrorism Government entities making payments to entities that have directors or FGAD22 shareholders suspected to be linked with terrorism cheques or payments by a public entity being cashed out and subsequently deposited to accounts of public officials or entities related FGAD23 to public officials. Public officials, especially those having a role in government contract management or public procurement of high-value assets, receive funds transfer instructions from business and/or personal accounts, where FGAD24 these funds appear to be excessive in value Public officials, especially those having a role in government contract management or public procurement of high-value assets, receive funds transfer instructions from according to in-built distribution methods or FGAD25 contractors or intermediaries; Public officials, especially those having a role in government contract management or public procurement of high-value assets, receive funds transfer instructions from distributors used at the request of the FGAD26 contracting party; Public officials, especially those having a role in government contract management or public procurement of high-value assets, receive funds transfer instructions according to existence of rebate arrangements, particularly if agreed outside the contract under requirements to obtain licenses and other government permits as a pre-requisite of doing FGAD27 business. Funds received in accounts of persons, legal entities, or legal arrangements with no visible connection to public officials, but known to FGAD28 be controlled by such, or persons related to them Representative of a public official (i.e. lawyer, secretary, accountant) opens account and purchases expensive property or luxury goods with the express intent of bypassing Customer Due Diligence (CDD) process FGAD29 screening for public officials. Travel patterns that mirror smuggling patterns of illegal goods (i.e. drugs) FXCD1 and human being trafficking routes;

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Item Description The customer is unwilling to provide routine information when requested or the information provided is insufficient, false, or hard for the currency FXCD2 exchange/ money remitter verify. High percentage of criminal activity corridor business, where the location is susceptible to involvement in known criminal activity, such as drugs, FXCD3 prostitution, certain fraud, etc. A customer sends/receives funds to/from counterparts located in jurisdictions which are known to be exposed to risks of, i.e. drug trafficking, FXCD4 terrorism financing, smuggling. Customers send or receive (regular) payments from countries which are FXCD5 regarded as “tax havens” or non-co-operating. The sender/beneficiary has no relation to the country where he/she FXCD6 sends/receives the money and cannot explain the source of money. An under-aged person receives funds from many legal/natural persons FXCD7 and/or from different locations. The amount of the transaction is unusually large for the typical customer FXCD8 or for currency exchange. FXCD9 There is no genuine reason for the customer to use the services of a BDC. Transactions are accompanied by information which appears clearly false FXCD10 or contradictory. Repeated requests from a BDC for foreign exchange selling transactions in the amounts slightly less than the transaction limit for identification in a FXCD11 short period of time. FXCD12 Frequent shipping of parcel to high risks countries The rate of exchange is below or above the prevailing market rate at the FXCD13 time of the transaction. FXCD14 Large transfers from government account to Bureau De Change (BDC) Sudden increases in the frequency/value of transactions of a particular FXCD15 customer without reasonable explanation. Customer sends frequent wire transfers to foreign countries , but FXCD16 business does not seem to have connection to destination country. Customer’s area of residence is inconsistent with other profile details such FXCD17 as employment. The customer is known to have a criminal past or is close to a person who FXCD18 is known to have a criminal past. A customer refuses to identify a legitimate source for funds or FXCD19 information that is false, misleading or substantially incorrect. The customer, without a plausible reason, repeatedly goes to BDC located FXCD20 far from his/her place of residence or work. There is no link between the amount of money exchanged and holiday FXCD21 periods FXCD22 A customer exhibits a total lack of concern for transaction costs. Requests to purchase, or possession of, large amounts of foreign currency FXCD23 without a plausible explanation. The size of the shipment appears inconsistent with the scale of the FXCD24 exporter or importer’s regular business activities.

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Item Description The method of payment appears inconsistent with the risk characteristics FXCD25 of the transaction. The amount of foreign bank transfers for imports of an entity reveal FXCD26 significant mismatches to taxes paid for the import activities. Underlying documents appear to be counterfeits / customs documents FXCD27 bear signs of having been falsified. Large payments in round figures are sent / received from bank account of newly established entities for commercial reasons, which appear FXCD28 questionable. Invoices contain divergent information, e.g. contradictions between name FXCD29 of supplier and name of recipient of the payment. The entity is registered at an address likely to be a mass registration FXCD30 address, e.g. residential buildings, letterbox addresses, etc Payments for a trade transaction are made via transit accounts in FXCD31 countries not involved in the trading. FXCD32 Shipping route is not cost effective The value on registered imports of an entity reveal significant mismatches FXCD33 to the entity’s volume of foreign bank transfers for imports. Personal funds sent through Money Value Transfer Services at a time not FXCD34 associated with salary payments. Receipt of financial support (or paid-for expenses and assets) from an FXCD35 unexpected or undefined source Foreign currency transfers to or from conflict zones or FXCD36 neighboring regions Movement of foreign currency entirely unrelated to employment or other FXCD37 financial arrangements FXCD38 Payments for travel to and from conflict zones or neighboring regions Large or frequent donations to charities with connections to conflict zones FXCD39 or neighboring regions Payments to media outlets or bookstores associated with propagating FXCD40 radicalism , extremism or violence A change in currency usage such as a sudden shift to financial instruments FXCD41 that are less transparent Buying or selling high value goods (e.g. cultural property) from conflict FXCD42 zones or neighboring regions FXCD43 Travelling to and from conflict zones or neighboring regions FXCD44 Fund transfers to or from conflict zones or neighboring regions Large or repeated transfers between the account of a legal person and a FXCD45 private account, especially if the legal person is not a resident. Risky goods such as high value goods and dual-use goods in unexpectedly FXCD46 high quantities Numerous incoming or outgoing money flows into business accounts with FXCD47 no apparent legitimate business purpose Lack of documentation regarding the purpose, source, or destination of FXCD48 the foreign currency

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Item Description Deposit transactions are located at a great geographical distance from FXCD49 where the accounts or owners are domiciled. Large amounts are transferred to companies abroad with a service FXCD50 provider address. FXCD51 Conducting transactions before or after business hours. Customers send or receive (regular) payments from countries which are FXCD52 regarded as “tax havens” or non-co-operating . Transfer of funds from the sender to the recipient with the same name FXCD53 (same beneficiaries) Individuals/Persons who receive funds from persons who have no ILA1 apparent relationship (e.g. a foreigner sending money to a Nigerian). Wire transfers/remittances from high risk jurisdictions (terrorism, drugs ILA2 or high crime rates) Persons on UN list, Sanction list, PEPs, or other prohibited lists receiving ILA3 funds into their accounts. Newly registered companies with similar names or acronyms to major ILA4 international or local companies receiving huge funds into their accounts. Corporate entities receiving huge inflows from ML tax havens for ILA5 investments ILA6 Requests to Communicate with WhatsApp, IM, Text, etc. ILA7 Unexplained urgency ILA8 Last minute changes in wire instructions or recipient account information Last minute changes in established communication platforms or email ILA9 account addresses Communications only in email and refusal to communicate via telephone ILA10 or online voice or video platforms ILA11 Requests from employees to change direct deposit information Persons between the ages of 18-40 receiving funds for upkeeps, school ILA12 fees and medical fees from persons with no apparent relationship. ILA13 Poorly crafted e-mails with spelling and grammar mistakes ILA14 Discrepancies noticed on shipping documents ILA15 Products or options do not correspond with purported line of business ILA16 No obvious use for commodity ILA17 Shipping route does not make economic sense (i.e., not cost effective) ILA18 Shipment going to a known or suspected transhipment country Shipment is purchased by firms or individuals from foreign countries other ILA19 than the country of the stated end-user of the product ILA20 Difficulty in determining the ultimate consignee of the commodity ILA21 Offshore broker with no identified office Individuals located in certain geographical locations receiving funds from ILA22 persons with no apparent relationships. ILA23 Inadequate KYC on customers, with no limit on investments ILA24 Individuals receiving remittances from multiple unrelated persons.

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Item Description Persons who appear to be reluctant or annoyed when asked to provide appropriate identification or to fill out the application forms that are ILA25 required when receiving an international wire transfer. Persons who provide accounts of other people in order to receive wire ILA26 transfers/remittance. Persons who transfer immediately to third parties’ remittances received ILA27 into their accounts. Newly opened account of entities receiving huge/sudden foreign transfers ILA28 without any apparent economic justification. New customer receiving huge wire transfers into its account from foreign ILA29 jurisdictions. LGAAR1 Cash withdrawals from Joint State Local Government Account State Government opening another or multiple accounts with Similar name as State Joint Local Government Account, like State Joint Local Government Main (or Project) Account and transferring Local LGAAR2 governments allocations to the latter account Unusual payments into accounts controlled by State Government Officials LGAAR3 like Ministry of Local Government and Chieftaincy Affairs LGAAR4 Payments into ALGON Accounts LGAAR5 Payments into multiple accounts of same Local Government Payments from Joint State Local Government Account into dormant LGAAR6 accounts Payments from Joint State Local Government Account to humanitarian LGAAR7 purposes directly State Government opening a new Joint State Local Government Account LGAAR8 to receive Local Governments allocations State Government opening another account with a similar name to Joint State Local Government Account to which monies are transfer Real Estate LGAAR9 Development as soon as they hit the JAAC account LGAAR10 Transfers to BDCs from Joint State Local Government Account Inflows to Joint State Local Government Account that are neither from the Federation Account nor the percentage Local Government share of the LGAAR11 internally generated revenue of the State Payments from Joint State Local Government Account to Individual or LGAAR12 companies Account LGAAR13 Unexplained depositor to Joint State Local Government Account Payments made directly from Joint State Local Government Account for LGAAR14 pilgrimage and to vague entities. Payments for the purchase of gold or other precious metals from Joint LGAAR15 State Local Government Accounts Payments through informal value-transfer systems, like Hawalas from LGAAR16 Joint State Local Government Accounts Unwillingness to provide explanation of financial activity from Joint State LGAAR17 Local Government Accounts Payments into dormant accounts from Joint State Local Government LGAAR18 Accounts

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NFIU XML Reporting Instructions and Specifications

Item Description Payments into a recently-formed legal entity from Joint State Local LGAAR19 Government Accounts LGAAR20 Unexplained source of funds into Joint State Local Government Account Deductions from State Joint Local Government Account before payments LGAAR21 to Local governments LGAAR22 Piecemeal Payments into Local Government Accounts Payments from Joint State Local Government Account into Accounts not LGAAR23 belonging to Local governments Payments from into Joint State Local Government Account into accounts LGAAR24 of Illegally-created Local Councils that are not constitutional recognized ISPO or other loans taken by the State government and its repayment LGAAR25 charged on inflows on JAAC Payment of Allocations to one Local government in favour of other Local LGAAR26 Governments MA1 Huge inflows into minor accounts for savings towards children education Legal persons or legal arrangements have authorized numerous MA2 signatories without sufficient explanation or business justification Legal persons or legal arrangements are incorporated/formed in a jurisdiction that is considered to pose a high money laundering or MA3 terrorism financing risk Legal persons or legal arrangements are incorporated/formed in a low-tax MA4 jurisdiction or international trade or finance center Legal persons or legal arrangements regularly send money to low-tax MA5 jurisdictions or international trade or finance center Legal persons or legal arrangements conduct a large number of MA6 transactions with a small number of recipients Legal persons or legal arrangements conduct a small number of high-value MA7 transactions with a small number of recipients Legal persons or legal arrangements regularly conduct transactions with MA8 international companies without sufficient corporate or trade justification Legal persons or legal arrangements receive large sums of capital funding quickly following incorporation/formation, which is spent or transferred MA9 elsewhere in a short period of time without commercial justification Legal persons or legal arrangements maintain a bank balance of close to MA10 zero, despite frequent incoming and outgoing transactions Legal persons or legal arrangements conduct financial activities and MA11 transactions inconsistent with the corporate profile Payment of huge funds into reactivated accounts by individuals for MA12 educational purposes. Transfer of illicit funds in the country of origin by means of an informal MA13 money transfer system i.e. HAWALA system Seeking a loan from a financial system after constituting funds of illicit MA14 origin. MA15 Smurfing: several transactions and transfers from different locations. MA16 Payments or transfer of funds using third party’s accounts

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NFIU XML Reporting Instructions and Specifications

Item Description International transfers using complex corporate vehicle and shell MA17 companies Inbound transfers to accounts which are inconsistent with the business of MA18 the account owner Transaction involving persons/entity alleged of involvement in extortion MA19 and employment scams Foreign transfers/foreign remittance via Money Gram, Western Union and MA20 other Money Transfer Services without economic justification Sudden reactivation of a dormant account followed by unusual MA21 transactions MA22 Frequent inflows from Government Institutions MA23 Educational institutions receiving large funds in the name of scholarship. The subject/entity transfer incoming third-party deposits to numerous MA24 accounts The subject/entity receives many incoming cheques or wire transfers from MA25 unrelated third parties. The subject/entity makes numerous outgoing payments to third parties close in time to when the he/she/they receive many incoming third-party MA26 cheques or wire transfers Transfer to or from off-shore zones usually described as loans or credit MA27 reimbursement Beneficial owners difficult to identify and/or located in off-shore MA28 jurisdictions The use of bank accounts of natural person and offshore companies to MA29 make transaction Cases where a transaction involves payment made with the use of forged currencies or securities and/or stolen currencies and securities and where the counterparty thereto is suspected of being aware of the fact that forged currencies or securities and/or stolen currencies or securities were MA30 used A transaction involving a customer who attaches unduly high importance to transaction confidentiality or a customer who has requested the financial institution not to report his or her transaction or who tries to prevent the financial institution from reporting it by using force or by MA31 paying bribes. When the account holder is reluctant to provide or refuses to provide information, data and documents usually required in order to enable the MA32 execution transaction. Inconsistent information such as multiple tax IDs or unverified MA33 documents. Donation from foreign jurisdiction in disguise of making education MA34 accessible usually by private individuals particularly Nigerians in Diaspora. Complex financial transactions that are designed to conceal the source MA35 and ownership of the funds. Electronic fund transfers received from one jurisdiction may be requested MA36 to be transferred to beneficiaries’ accounts in another jurisdiction.

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Item Description MA37 Documents such as import permits produced appear to be forged Transactions conducted by Politically Exposed Persons (PEPs) for the MA38 purpose of establishment of private schools. Transaction from private individuals to other entities/individuals in the MA39 name of sporting activities. MA40 Purchase of money orders to pay bills instead of writing personal cheques Simple banking relationships are established using professional MA41 intermediaries. Legal persons or legal arrangements have declared an unusually large MA42 number of beneficiaries and other controlling interest Payments to or from accounts at financial institutions that are unrelated MOMCA1 to a transaction or approved counterparties Huge Payments from Oil and Gas to beneficiaries outside the line of MOMCA2 business of the customer Non-bank financial mechanisms such as currency exchange businesses or MOMCA3 money remitters. Precious Metal dealers dramatically increasing purchase of Precious MOMCA4 Metals for no apparent reason. Foreign nationals purchasing Precious Metals through multiple MOMCA5 transactions over a short time period Unusual pattern of Precious Metal transactions and the nature of the MOMCA6 transactions are inconsistent with the customer profile. Precious metals shipped to or from a jurisdiction designated as ‘high risk’ MOMCA7 for money laundering activities Movement of huge funds between Oil and Gas companies with the same MOMCA8 beneficial owners MOMCA9 Frequent early repayment of loans by Oil and Gas Companies MOMCA10 Huge payments from Oil and Gas companies to individuals Involvement of international trade companies, including import-export, freight forwarding, customs clearance, logistics, or similar types of companies operating in raw or squaReal Estate Development wooden logs, plastic waste or pellets, frozen food, fish maws, various kinds of NEWTC1 beans, stone or quartz blocks International wire transfers from known wildlife traffickers to a relative’s NEWTC2 accounts as tuition, allowance, or family support payments Use of common containers, consignees, transporter, clearing agents, or exporters as seen in other cases believed to involve international wild life NEWTC3 trade Activity involving PEPs and wealthy businessmen/women, particularly those with environmental, game, or forestry oversight or environmental NEWTC4 or wildlife related businesses Financial activities of Individuals or beneficial owner(s) of a corporate entities domiciled in jurisdictions that are prominent transit or demand NEWTC5 countries for illegal wildlife Illogical or anomalous loans between trading or import/export companies NEWTC6 in key International wild life source or transit countries

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Item Description Transactions from known traffickers to individuals who then pay for NEWTC7 couriers or packages via the post Third-party wire transfers/cash deposits to, or withdrawals by, known NEWTC8 wildlife poachers and traffickers Transactions between licensed pet shop suppliers/breeders and known NEWTC9 wildlife poachers and traffickers Transactions to licensed pet shop suppliers/breeders that originate from NEWTC10 overseas, and/or incommensurate with stated business activities P_Offence1 Advance Fee Fraud (419) P_Offence2 Concealment of Assets P_Offence3 Forgery P_Offence4 Piracy P_Offence5 Market Manipulation P_Offence6 Insider Dealing P_Offence7 Cheque suppression P_Offence8 Money Laundering P_Offence9 Identity theft P_Offence10 Robbery or Theft P_Offence11 Environmental Crimes P_Offence12 Business e-mail compromise (BEC) P_Offence13 Drug trafficking P_Offence14 Human Trafficking and Trafficking in persons P_Offence15 Oil bunkering P_Offence16 Illicit traffic in narcotic drugs and psychotropic substances, P_Offence17 Participation in an organized criminal group and racketeering P_Offence18 Illicit arms trafficking P_Offence19 Round tripping of foreign currencies P_Offence20 Illegal bunkering P_Offence21 Counterfeiting currency P_Offence22 Romance scam P_Offence23 Counterfeiting and piracy of products P_Offence24 Kidnapping P_Offence25 Smuggling P_Offence26 Extortion P_Offence27 Cyber crime P_Offence28 Illegal Mining P_Offence29 Theft of Mined Ore. P_Offence30 Misrepresentation/fraud. P_Offence31 Illicit trafficking in stolen petroleum products P_Offence32 Wire fraud P_Offence33 Piracy for ransom P_Offence34 Counterfeiting and piracy of petroleum products

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Item Description P_Offence35 Invoice fraud P_Offence36 Crude oil theft P_Offence37 Over- and under-shipment of goods by exporter P_Offence38 Multiple invoicing of goods by exporter P_Offence39 Smuggling using vessel. P_Offence40 Narcotics P_Offence41 Credit card fraud P_Offence42 Armed Robbery P_Offence43 Proliferation of weapons P_Offence44 sexual exploitation P_Offence45 kidnapping and hostage taking P_Offence46 Terrorism P_Offence47 Terrorist Financing P_Offence48 Bribery P_Offence49 Illicit trafficking in narcotic drugs and psychotropic substances P_Offence50 Inheritance Fraud P_Offence51 Insider trading Sexual exploitation, including sexual exploitation of children and P_Offence52 prostitution P_Offence53 Illicit trafficking in stolen and other goods P_Offence54 Murder P_Offence55 Kidnapping, illegal restraint and hostage-taking P_Offence56 Tax Crimes P_Offence57 Tax Evasion P_Offence58 FOREX Scams P_Offence59 Smuggling (in relation to custom and excise duties taxes) P_Offence60 Abuse of Office P_Offence61 Vote Buying P_Offence62 Corruption, Bribery and Embezzlement of funds P_Offence63 Fraud Single large inflow that are 25% above annual average inflow to Real RECSO1 Estate Development account Inflows from INVESTMENT Companies into a Real Estate Development RECSO2 account Inflows of N5,000,000.00 and above from a PEP to a Real Estate RECSO3 Development Account RECSO4 Inflows from N10,000,000.00 from a Non-Profit Organisation RECSO5 Inflows from an entity/subjects without a TIN Pre-liquidation of mortgage loans with outstanding balance above RECSO6 N10,000,000.00 Transfers of amounts from N9,500,000.00 to BDC at a frequency of more RECSO7 than (3) in a day

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Item Description More than five (5) inflows of amounts above N9,500,000.00 from the RECSO8 same entity in a year into a Real Estate Development account Inflow into a Real Estate Development account of amount above N5,000,000.00 from an individual that has their year of birth as 1995 or RECSO9 later Inflow into a Real Estate Development account of amount above N10,000,000.00 from an entity with incorporation date not more than 12 RECSO10 months from transaction date All pre-liquidation of developer loans with outstanding balance of RECSO11 N100,000,000.00 and above Single large outflow that are more 25% above the size of the average RECSO12 annual transaction outflow of the Real Estate Development RECSO13 Real Estate Developer without a Tax Identification Number RECSO14 Real Estate Developer without SCUML registration number Foreign currency inflow of $100,000.00 into a Real Estate Development RECSO15 account Transfer of funds from State Government account to Bureau De Change SGAD1 operators. Sudden huge inflows of funds originating from State Governments into SGAD2 dormant accounts SGAD3 Contract payment directly from JAAC. Movement of funds from JAAC to the State Government signatories’ SGAD4 account. Transfer of funds from JAAC to companies without any economic SGAD5 justification. Repatriation of funds from Local Government accounts back to State SGAD6 Government related accounts. SGAD7 Transfer of funds from FAAC to a potential signatory of Sate Government. SGAD8 Transfer of funds from JAAC to individuals’ account. State Government paying “Protection Fees” to groups or individuals with SGAD9 links to terrorism. SGAD10 Transfer of state government funds to Tour companies. Huge unexplained lodgements into person accounts by public servants at SGAD11 State Government level SGAD12 State governments commercial investment promotion by BDC operators SGAD13 Transactions of PEPs related BDC promoters Multiple deposits funds into BDCs account by government official instead SGAD14 of that of the government account High volume of transactions within a short period without any verifiable SGAD15 reason Transactions from State Government accounts into non-profit SGAD16 organizations. Frequent early repayment of loans by public servant at State Government SGAD17 level Structuring of employee salaries/entitlements to allocate substantial TRML1 amount payable to non-taxable incomes/sub-heads Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 77 of 82

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Item Description TRML2 Frequent amendment and rejection of letters of credit (LCs) by entities Use of common address and bank accounts by several people and TRML3 corporations. Establishment of operating company in another jurisdiction bearing the TRML4 same name without a commercial justification Round-tripping or circular transactions where funds are reinvested into the original jurisdiction after being deposited in a foreign entity (often in a TRML5 tax haven with no record keeping requirements) Frequent and substantial wire transfers from/to high tax jurisdiction TRML6 without a legitimate commercial purpose Acquiring loans and other credit facilities from an offshore company TRML7 (especially from a parent company) to a subsidiary company Under invoicing of goods and services from source country (exporting) to enable under or non-payment of appropriate taxes in the destination TRML8 (importing) country Post Office Box addresses being used, or the use of non-existent addresses, e.g., residence, employer address, etc.; or the postal code for TRML9 the client or employer is not consistent with the address given. TRML10 Business not located where person lives. Tax refunds mailed to address other than that listed on tax return as TRML11 residence of taxpayer. TRML12 Award of bonuses that seem to exceed industry expectations TRML13 Tax refunds sent to post office/mail boxes rather than a real address Source of funds is not sufficiently explained, or seems unusual in that it is not derived from a history of investments, commercial gain or family TRML14 wealth. Overstatement of expenses in financial records of corporate entities with TRML15 high turnover Sudden increase in volume of transactions evidenced by large income TRML16 inflows without corresponding increase in tax payments TRML17 Transactions involving tax havens . Frequent financial transactions via special purpose vehicles (SPVs) or TRML18 special purpose entities by companies and individuals Deposit of funds into an account which is found to be under a nominee TRML19 name TRML20 Evidence of investments in interrelated companies Company or individual known to be currently under investigation for any TRML21 money laundering predicate offence. Transactions involving certain high-risk jurisdictions such as locations in the midst of or in proximity to, armed conflict where terrorist groups CFT1 operate or locations which are subject to weaker ML/TF controls. An account opened in the name of an entity, a foundation or association, CFT2 which may be linked or involved with a suspected terrorist organization. The use of funds by a non-profit organization is not consistent with the CFT3 purpose for which it was established. CFT4 Raising donations in an unofficial or unregistered manner. Nigerian Financial Intelligence Unit goAML 4.5 Schema Page 78 of 82

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Item Description Client identified by media or law enforcement as having travelled, attempted or intended to travel to high-risk jurisdictions (including cities or districts of concern), specifically countries (and adjacent countries) under conflict and/or political instability or known to support terrorist CFT5 activities and organizations. Transactions involve individual(s) or entity (ies) identified by media and/or sanctions lists as being linked to a terrorist organization or terrorist CFT6 activities. Law enforcement information provided which indicates individual(s) or CFT7 entity (ies) may be linked to a terrorist organization or terrorist activities. Client conducted travel-related purchases (e.g. purchase of airline tickets, travel visa, passport, etc.) linked to high-risk jurisdictions (including cities or districts of concern), specifically countries (and adjacent countries) under conflict and/or political instability or known to support terrorist CFT8 activities and organizations. Individual or entity’s online presence supports violent extremism or CFT9 radicalization. Client donates to a cause that is subject to derogatory information that is publicly available (e.g. crowd funding initiative, charity, non-profit CFT10 organization, non-government organization, etc.). Transaction involving countries and jurisdictions under UN, OFAC and CFT11 other related sanctions list Transactions with jurisdictions that are known to be at a higher risk of CFT12 ML/TF. Transaction/business activity involving locations of concern, which can include jurisdictions where there are ongoing conflicts (and periphery areas), countries with weak money laundering/terrorist financing controls, or countries with highly secretive banking or other transactional CFT13 laws. Transactions involving any countries deemed high risk or non-cooperative CFT14 by the FATF. Client makes frequent overseas transfers, not in line with their financial CFT15 profile. Newly-opened customer account appears to be controlled by a third party, including forms completed in different handwriting and/or the CFT16 customer reads their address from a form. Lack of living expenses such as food, petrol, utilities and rent (one utility CFT17 may be set up for the purposes of confirming ID for account opening). CFT18 One-way flight purchase from high-risk country by non-family member. CFT19 Payment for visa by non-family member. Payments to labour agencies, recruiters or employment websites, CFT20 especially if those entities are based overseas. Repeated (at least weekly) transfers of funds to the same third party CFT21 (where known), often in round amounts. CFT22 Signs of bruising or other physical abuse on customer CFT23 The customers receive weekly incomes from an agency

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Item Description CFT24 Use of an interpreter at account opening or for conducting transactions CFT25 Funds transfers received from or to the benefit of unrelated third parties Involvement of items controlled under WMD export control regimes or CFT26 national control regimes. Involvement of a person connected with a country of proliferation concern (e.g., dual use national), and/or dealing with complex equipment CFT27 for which he/she lacks technical background. A user who is unable to provide strong evidence of sources of VIRTUAL1 wealth/source of funds in respect to the amount of virtual assets. A user’s portfolio only consists of or has a high value of privacy coins (e.g., VIRTUAL2 Monero, Dash, Zcash). A user has a long period of dormancy followed by a large volume/velocity VIRTUAL3 of transactions. Paying and/or willingness to pay high commission fees for converting (selling) virtual assets in exchange for fiat, compared to commission fees VIRTUAL4 typically charged by virtual assets exchanges. A user receives frequent and/or large value transactions from Bitcoin VIRTUAL5 ATMs. A user is involved in conducting, or involved with organizations VIRTUAL6 conducting, virtual assets mining operations. VIRTUAL7 Use of Virtual Private Network (“VPN”) and/or The Onion Router (“TOR”). A user is registered with encrypted, anonymous email or a temporary VIRTUAL8 email service (e.g., protonmail.com and tutanota.com). Requests from law enforcement or government authorities where a user’s information has been requested as part of an investigation, or VIRTUAL9 requests/legal orders to freeze a user’s funds. Negative media or open source research reveals that the user is believed VIRTUAL10 to be involved in illicit activity. VIRTUAL11 A user admits or makes statements about involvement in illicit activities. Funds deposited soon after account registration and withdrawn again shortly thereafter in the same virtual asset without using platform features (e.g., trading/ margin funding) – may be indicative of a platform VIRTUAL12 being used as a mixer/tumbler. Funds are primarily sent to or received from P2P exchanges without using VIRTUAL13 the platform’s features, particularly fiat-based services. Outgoing funds to newly created and heretofore never used virtual asset VIRTUAL14 addresses. Funds deposited from or withdrawn to a virtual asset address with direct and indirect (e.g., few hops removed) links to known suspicious sources, including darknet marketplaces, mixing/tumbling services, questionable gambling sites, wallets known to be involved in illegal activities (e.g. VIRTUAL15 ransomware) and/or theft reports. Funds in a user account have been reported stolen or otherwise reported VIRTUAL16 to have been obtained illegally. Funds move from an illicit source through numerous intermediary VIRTUAL17 addresses over a short period of time before being deposited with a VASP.

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Item Description A user submits comments for transactions (e.g., withdrawals) which may VIRTUAL18 refer to illicit activity. Depositing virtual assets and withdrawing funds in fiat currency and vice- VIRTUAL19 versa, without utilizing any platform services. A user requests a withdrawal to be processed unreasonably quickly or VIRTUAL20 outside of a company’s terms of service (“ToS”). A user receives a large proportion of funds directly from a mixer/tumbler VIRTUAL21 without pre-advising the receiving VASP. A user sends a large proportion of funds to a mixer/tumbler without pre- VIRTUAL22 advising the sending VASP. A single ATM processes inexplicably high values of transactions in a short VIRTUAL23 time period. Funds flow through a large number of intermediate addresses in a very short period of time prior to being deposited in a customer’s wallet, or just after being withdrawn, and where the ultimate source or destination VIRTUAL24 is an illicit entity. A user frequently receives funds from, or sends funds to, darknet wallet VIRTUAL25 addresses that accumulate to large values. A significant percentage of a user’s deposits to an exchange originate VIRTUAL26 from darknet marketplaces. A significant percentage of a user’s withdrawals from an exchange VIRTUAL27 ultimately result in transactions with darknet marketplaces. Indirect exposure to darknet marketplaces is identified (i.e., the funds moved from a darknet wallet through two or more hops to the user’s VIRTUAL28 wallet in a short time frame in similar amounts). A user is found on open source forums or other sites that connect the VIRTUAL29 user directly or indirectly to darknet markets. VIRTUAL30 Direct exposure to the darknet marketplace is identified. A user is found to have been connected to TOR through the user’s IP VIRTUAL31 address or Internet Service Provider (“ISP”). Bitcoin ATM withdrawals are made from high-risk geographies or areas VIRTUAL32 with high crime rates. A user exploits technological glitches/failure in an effort to intentionally VIRTUAL33 take advantage of a platform or obtain funds. A user conducts trades in such a way that creates a negative balance or reduces equity in one account, in order to increase equity or create a VIRTUAL34 positive balance in another account operated by the same user. A user conducts transaction that appear to be inconsistent with the user’s VIRTUAL35 KYC, transaction history/patterns and/or market trends. A platform receives unusual/demanding requests from other exchanges/vendors/ service providers in respect to a user’s funds VIRTUAL36 deposited on a platform. Transactions with jurisdictions known to be used to circumvent sanctions VIRTUAL37 or used in trade-based ML schemes.

Table 40: Indicator type

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5.20 Gender type

Item Description F Female M Male - Unknown Table 41: Gender Type

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