High-Risk Transactions EBA “The ML/TF Risk Factors Guidelines” (EBA/GL/2021/02) Unusual transactions 4.60. Firms should put in place adequate policies and procedures to detect unusual transactionsor patterns of transactions. Where a firm detects such transactions, it must apply EDD measures. Transactions may be unusual because: 4.61. These EDD measures should enable the firm to determine whether these transactions giverise to suspicion and must at least include: Section 15 (3) no. 3 of the German GwG A higher risk arises in particular if the transaction, in relation to similar cases, Section 15 (6) of the German GwG In the case of high-risk transactions, at least the following … Continue reading High-Risk TransactionsRead More →