Suspicious Transactions Types
Legal Framework of STR
Definition of Suspicious Transaction
Those who are obliged to Report Suspicious Transac...
Confidentiality of Reporting
Protection of Obliged Parties
The Time Allowed For Reporting Suspicious Transact...
Submission of Suspicious Transaction Reports by Ha...
Submission of Suspicious Transaction Reports Elect...
Principles and Procedures for Suspicious Transacti...
Period in Suspicious Transaction Reporting
Sanctions to be Implemented in Violation of STR O...
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Suspicious Transactions Types


1. Types Related to Customer Profile

1.1. Inadequate information in the documents required to be presented or submitted by customers, inconsistent information or reluctance to give information while applying to the obliged parties.

1.2. A concrete reason to suspect such as negative news in the media about the customer on laundering proceeds of crime or financing of terrorism, or offering money or gifts for the transaction to be carried out.

1.3. Showing different customer attitude other than general customer attitude models, for example: behaving too friendly or having threatening attitude in order to prevent suspicious transaction reporting about them.

1.4. An unreasonable proportion between job/profession, financial profile and transactions of the customers.

1.5. Commercial or any other type of relationship of customers with risky persons or institutions.

1.6. Unusual capital, partnership, management or employment structure of companies compared to other institutions in the same sector or general company structures.

2. Types Related to Transactions

2.1. Single transactions of persons or institutions carrying out commercial activities which should normally be repeated within the scope of those commercial activities, or repeating transactions that are normally not conducted constantly in the ordinary commercial world.

2.2. Carrying out financial transactions, which are required to be conducted as one single transaction in usual cases, by dividing the amounts in smaller pieces without a reasonable ground in order to abstain from customer identification and reportings.

2.3. No usual and reasonable legal or economic ground or reason in conducted or requested transactions.

2.4. Customer using means of payment unusually such as by making too many cash payments with small denominations or making payments in a foreign exchange used infrequently.


3. Types Related to Banking Sector
Indicators Related to Suspicious Behaviors of Customers and Submission of Inadequate- Misleading-False Information and Documents

3.1. The customer trying to gather information and asking questions before carrying out a transaction to learn about customer identification and suspicious transaction reporting obligations, transaction limits, control methods of the bank for combating money laundering.

3.2. Having difficulties in receiving information from the customer about his/her activity, profession, or personal information such as identity, address, telephone.

3.3. The customer having difficulty in explaining the aim of the transaction or the source of the fund subject to transaction, or abstaining from giving information.

3.4. The customer trying to persuade the bank clerk to allow him/her not to submit or fill in a document which is legally or administratively required to be submitted or filled in.

3.5. The customer demanding to open accounts in the name of numerous people residing in Turkey or abroad, or depositing or withdrawing constantly cash to/from accounts opened in the name of third parties without a reasonable and acceptable reason.

3.6. The account holders having insufficient information about the amount deposited to their accounts or the amount in their accounts.

3.7. The customers, apparently acting independently, giving the same address, telephone or similar contact information, sending remittances to the same beneficiary or receiving remittances from the same originators, or giving the signing authority to same person or persons in the accounts they open.

3.8. The customer hiring a joint safe box with people who are not family members, relatives or business partners or giving them power of attorney to use these safe boxes; an excessively intensive use of safe boxes indicating that they are used as money safe boxes by several persons; intensive use of safe boxes by customers who do not have considerable account relationships or transaction volumes; safe boxes hired in the name of different persons short before or after considerable transactions; commercial institutions hiring safe boxes although their business field does not require doing so.

3.9. Remarkable and intensive cash transaction or electronic transfer traffic directed from Turkey or abroad conflicting with safe deposit profile in accounts of persons who opened joint time deposit account although they do not have any family or business relationship.

3.10. Understanding that the natural or legal persons who are apparently partners or managers of legal person customers are not real partners or managers of the company; Knowing or having a reasonable ground to suspect that the capital and administration of the company is held by third persons who have bad reputation or against whom a case was filed or an investigation is run by official administrations.

3.11. The new reigning partner and/or partners of the legal person customers abstaining from giving information about their personal and commercial backgrounds; having indications that they did not have any interest, education and experience in the field in which the company operates.
Indicators Related To Evading Procedures of Customer Identification, Record Keeping and Reporting

3.12. The customer attempting to open an account suspected to be counterfeit-fictitious, make transaction or have somebody make transaction on behalf of others or through accounts without submitting ID- Card or acceptable ID- Card.

3.13. Making an offer, threatening and putting pressure on the staff of obliged party by the customer in order not to report suspicious transaction.

3.14. The customer attempting to carry out transaction under a certain threshold for the purpose of abstaining from reporting procedures, division of the money, subject to the transaction attempted, into more than one transaction, account, remittance or cash transaction.

3.15. Existence of many accounts of a customer within various branches of the same bank with which similar transactions were carried out on behalf of himself/herself or third parties on behalf of whom he/she acted or understanding from account movements that similar accounts have also been opened in the other banks.

3.16. Making payments to the same account by a large number of persons without explaining reasonable statement or transferring money to the same account from many different accounts.
Indicators Related To Transactions in Cash Character

3.17. The banknotes brought by customers; being small denominated and dirty, existence of stains demonstrating that it has been carried concealing in various elements and giving off smell, packaged carelessly and precipitately, lacking or exceeding substantially than the declaration of customer when counted, coming across with counterfeit banknotes in the bankroll.

3.18. In the accounts of customer; observing cash withdrawals or deposit transactions (frequently in small amounts or in high amount for one time) in remarkable amounts which cannot be associated with the life standard, job and income level.

3.19. Transferring of money deposited to account abroad or domestic in pieces without making a reasonable statement or failing to act of the account a long time after such transactions carried out for a certain period.

3.20. Withdrawal of money continuously in cash which was came to the account opened as understood for only drawing of money transferred from abroad or failing to act of the account a long time after such transactions carried out for a short period.

3.21. Withdrawal of transfers, came to the low remaining inactive accounts of customer exist in more than one branch of the same bank, generally by maximum cash advance operation from ATMs.

3.22. Deposit or withdrawal of cash in large amounts to the accounts opened on behalf of enterprise, knowing that it was carried out without commercial motive, by the persons who do not have an apparent connection with commercial enterprise.

3.23. Customer’s investment or withdrawal of cash frequently in substantial amounts to the account in the same bank without taking into account the risks (except the reasonable factors) such as life safety, theft and abuse which can rise as a result of transportation of cash money.

3.24. Opening accounts with large amounts of cash by persons and institutions who do not have apparent economical reasons regarding the purpose of opening account and there is no enough information about them.

3.25. Customer’s request of arranging monetary instruments such as blocked cheques, letter of guarantee or payment orders by having held cash amounts in a bank frequently which are not related or which can not be associated with his business.

3.26. Fragmentary deposit of cash to the same account by the same persons via different branches or by the persons who come to the bank at the same time.

3.27. Investment of large amounts of cash to the account with a very low remaining and just after withdrawal of the invested cash or remittance to another account or accounts.
Indicators Related To Electronic Transfers

3.28. Making transfers in remarkable amounts at one go from or to risky countries or off-shores without making any reasonable explanation or frequent and low amounts of transfers which may reach significant amounts in a specific period.

3.29. Not making a reasonable statement relating to realization purpose of electronic fund transfers which are in conspicuous amounts and frequency or directed from risky countries, not filling up the blanks that the full name and addresses of supervisor and beneficiary in transfer messages or placing expressions such as nickname, code, abbreviation instead of real supervisors name in these blanks.

3.30. Making domestic or abroad electronic fund transfers in conspicuous frequency and amount which can not be associated with the known business and activities, sources and level of income of the customer.

3.31. Returning the incoming funds transferred from abroad to the accounts or the names of the customers with registered addresses inside or outside the country back to abroad after a short period of time, or the customer requesting from the bank clerk to transfer the amounts to abroad that he/she expects to be transferred from abroad but not entered into his/her accounts yet; similar amounts of funds entering into and exiting the country on close dates through such accounts used as transitory accounts.

3.32. The customer opening several accounts in the same kind of foreign exchange without any specific reason; especially transfering the funds which he/she brought in cash or which were deposited into his/her account in cash to the persons and organizations located in free trade zone or off-shores with whom there are no ostensible business relationships.

3.33. Opening of account for only the purpose of transferring money abroad, existing no information or insufficient information regarding the relationship between the persons the transfers were made.

3.34. The customer making indirect electronic fund transfers not associated with his/her personal and economical statute.

3.35. Receiving high amounts of remittances from an account newly opened after a short time from opening and not carrying out any other transactions relating to the incoming money for a long time.

3.36. Carrying out transactions in foreign exchange through wire transfers on behalf of a customer and with the persons or countries who have not any commercial relation with this customer by a third person.
Indicators Related To Credit Transactions

3.37. Guarantee letter requesting of real and legal persons who are not acknowledged by the bank for cash credit or goods purchase and taking no notice of bank commission, charges or interest rates by these persons.

3.38. The customer gives a check (high amounted and drawn on a foreign bank) as a guarantee to the bank which gave credit, containing contradictory information regarding the commercial activity where it was originated, not having a supportive document, not pertaining to a drawer and endorsers who can be correlated commercially, and who are associated with risky regions and countries about fraud and smuggling.

3.39. Using credits from the banks located in risky countries or demanding for credit pursuant to the letters provided from these banks.

3.40. Credit request of customer, without any reasonable grounds, providing collateral the assets of the companies registered or third parties resident in risky countries.

3.41. Credit request of customer, although he/she has significant assets, which is not rational for him/her providing the concerning assets as collateral.

3.42. Credit request of customer providing bearer instruments of which has indefinite resource or another asset having a suspicious (unknown) resource as collateral.

3.43. The potential credit customer acts unwillingly in determining the purpose of taking credit or refuses to explain the purpose or states a doubtful purpose.

3.44. Providing collateral, without basing on a reasonable ground, by third parties who are not known by the bank and not having affiliation with the customer.

3.45. Cash withdrawals of credit customers continuously in remarkable amounts, constant and/or extraordinary usage of credit cards in buying and selling of valuable goods such as gold which can be easily converted into cash.

3.46. Refunding of a credit, without basing on a reasonable ground and adventitiously, at once which is unexpired or having problems.

4. Types Related To Insurance Sector

4.1. The customer makes an application for the insurance of a risk which is not having a reasonable concern with the personality, business or wealth of the customer.

4.2. The customer requests policy in high amounts and single premium which is not accorded with the general status and financial profile of him/her.

4.3. The customer says he/she has also policies from other companies or determination of this and showing this situation incongruity with the financial profile of the customer.

4.4. The customer suggests purchasing insurance policy on behalf of a third party who is understood to be clearly disinterested with him/her or requesting transfer of insurance indemnity to the account of said party or asking for changing the beneficiary on behalf of the third party who is understood to be clearly disinterested.

4.5. The customer pays high amounts of pension or life insurance policies premiums by cash.

4.6. The customer, possessing policy based on minute quantity and regular payment, closes the remaining premiums of the policy abruptly by cash payment or proposes increasing in significant amount or purchases a new policy in high amounts.

4.7. Request of customer, without any reasonable grounds and by being aware of giving rise to a financial loss in considerable amount, the repayment of policy prior to its maturity or the payment to be made in favor of third parties.

4.8. Making the payment in single premium assurance contract via electronic transfer from a financial institution located in a risk country.

4.9. Application of customer for retirement plan or life insurance contract that is inconsistent with his/her age and physical condition.

5. Types Related To Capital Markets

5.1. The customer gives conspicuous orders which are unreasonable and mostly resulting with loss by giving the impression of not seeking profit, taking no notice of the risks and costs of investments, and carrying out transactions to this effect.

5.2. Credit usage of customer in remarkable amounts and non-proportional to his/her financial status or collateral provided for the credit by the third parties who has no relation with customer.

5.3. The customer abruptly closes the security credit he/she has taken before maturity without a situation concerning the market conditions or another reasonable cause.

5.4. Customer constantly transfers securities and/or cash to the accounts of the persons who have no relation with the customer within several intermediary institutions without any reason.

5.5. The customer purchases securities or other capital market instruments in remarkable amounts by using cash which can not be accorded with the familiar activities of him/her.

5.6. Transferring, immediately, of financial investments and/or proceeds of them to the third parties that there is no apparent relationship with the customer.

5.7. Prohibition imposed on transactions against the partners or founders of corporate customer by Capital Markets Board.

5.8. The customer carries out transactions which raise suspicion that it is acted for the benefit of person on whom transaction prohibition is imposed by Capital Markets Board.

6. Types Related to Exchange Offices

6.1. Repeated requests from an exchange office for foreign exchange purchasing-selling transactions in the amounts slightly less than the transaction limit for identification in a short period of time.

6.2. Carrying out purchasing-selling or exchanging transactions with foreign exchange in remarkable amounts.

6.3. Exchange of unusually large amount of small-denominated notes for those of higher denomination.

6.4. The banknotes brought by customers; being small denominated and dirty, existence of stains demonstrating that it has been carried concealing in various elements and giving off smell, packaged carelessly and precipitately, lacking or exceeding substantially than the declaration of customer when counted, coming across with counterfeit banknotes in the bankroll.

6.5. Requesting for converting large amounts of foreign exchange which is not convertible (or not frequently used) to another kind of foreign exchange or Turkish Liras.

7. Types Related to Money Lenders

7.1. In case where a deptor requests for a loan in return for his/her asset whose origin is suspicious (unknown).

7.2. In case where a debtor requests for an uneconomical loan eventhough he/she has large amount of asset.

7.3. In case where refunds are made through bearer cheques or cheques of a third party or cheques endorsed again and again or through large amount of cash.

7.4. Refunding an undue or problematic credit abruptly.

8. Types Related to Factoring Companies

8.1. In case where a firm (seller) who had transfered its claim derived from forward sale to the factor sells good or service to its customers who may be natural or legal persons (buyers) constantly for high prices according to market conditions.

8.2. In case where buyer firm pays off its termed debts exceeding its own financial capacity or makes commitment to pay its debts or in this circumstance seller firm gives guarantee that buyer firm will pay its debts.

8.3. In case where there is a suspicicon that buyer firm or seller firm may be shell companies or that there may be a fictitious transaction carried out between them.

8.4 In case where there is a suspicicon that whether the invoices submitted to factoring company are original.

9. Types Related to Financial Leasing Companies

9.1. Leasing machinery and equipment through financial leasing with inappropriate prices as to current market value or its foreseeable values.

9.2. Financial leasing payments amounts of which are much larger than usual ones requested or financial leasing payments reasons of which are not given.

9.3. Refunding financial leasing debts unexpectedly, before deadline and through unknown source.

9.4. Execution of the terms and payments of financial leasing contract by third parties or the persons supplying the goods subject to financial leasing without any reasonable ground in place of lessee.

10. Types Related to Consumer Finance Companies

10.1. In case where customer refunds the credit abruptly and makes payment with large amount of cash without any reasonable ground and particularly in a manner where he/she is exposed to large amount of material loss.

10.2. In case where customer requests for unprofitable credit for himself/herself in return for large amount of assets held by the customer.

10.3. In case where it seems that customer disregards of credit costs and maturity.

11. Types Related to Postal And Cargo Services And Cargo Companies

11.1. In case where it is detected that there is a different material in the parcel sent via postal or cargo service from the material declared by the sender.

11.2. Permanently sending precious stones, metals and valuable things like them to particular addresses apart from the traders or manifacturers of the related sector.

12. Types Related to Real-Estate Sector

12.1. In case where customer buys real-estate for third parties without any reasonable ground such as business or family relation.

12.2. In case where customer buys real-estate with high value which is not consistent with the financial status of the customer or buys several real-estates in a short time on which he/she does not make any search and which is not economical with regard to location and conditions and which requires large amount of maintenance cost.

12.3. In case where customer who wants real-estate agency to sell his/her real-estate requests the agency to indicate sale price more than the amount in the records.

12.4. In case where customer makes payment for rest of the money through extraordinary payment method after he/she makes advance payment with cash or leases the real-estate by using large amount of cash.


13. Types of transactions carried out with the persons or with risky countries suspected to be in connection with terrorist organizations

13.1. Opening an account, carrying out wire transfers or remittances on behalf of natural and legal persons that are known to be in relation with a terrorist organization.

13.2. Transferring the money, which is in amounts that have no commercial explanation or economical purpose, through wire transfer to a commercial account opened in risky countries and/or withdrawing this money from the account.

13.3. Transferring or receiving funds to and/or from risky countries, opening account within the financial institutions in these countries or using the credit cards issued by the banks located in those countries.

13.4. Transferring funds by third persons on behalf of customers through exchanging foreign currency to the countries in which terrorism and smuggling are seen frequently; or which are known as tax havens; and which have no clear business relation with the customer

13.5. Transferring to third persons the deposits accumulated in a short period of time as a result of the transfer transactions conducted from or through the risky countries.

13.6. Collecting funds especially from or into risky countries using a high number of individual or commercial accounts and directing those funds to a small number of beneficiaries.

13.7. In the fund transfers carried out from or to risky countries, using commercial financial transactions which have no reasonable commercial purpose.

14. Types of transactions related to non-profit organizations

14.1. In case where a mismatch is detected between the nature and size of financial transactions or amount of funds raised or transferred and the apparent sources, stated purpose and activities of the NPO.

14.2. In case where a sudden increase is detected in the frequency and amounts of financial transactions on the account of an NPO.

14.3. In case where NPO appears to keep funds in its account for a very long period.

14.4. In case where NPO receives donations only from abroad or significant part of the donations is originated from abroad.

14.5. In case where directors of NPO are foreign nationals; particularly existence of transactions with large amounts carried out by the directors to their own countries and also destination is a high-risk jurisdiction.

14.6. In case where NPO has unexplained links; for example, several NPOs transfer money to each other or share the same address, same managers or personnel.

14.7. In case where NPOs having no enough personnel, suitable offices or telephone numbers have large financial turnover as if they operate intensively.

14.8. Receiving funds by using several individual and commercial accounts or accounts of non-profit organizations and transferring these funds to foreign beneficiaries in a short period of time.