1. When serving customers under the Estonian licenses, the relevant employee shall follow Estonian
2. The relevant employee analysing the customer and his/her behaviour should undertake investigative
efforts that are proportional to the risk and complexity of the case and collect
evidence using observations gathered in the case.
3. If the relevant employee identifies any additional risks, they will need to conduct investigative
research to understand these risks in the context of the case.
4. Additional evidence will be needed to support the review and understanding if additional
risks are identified.
5. The following questions may help to determine whether a transaction is suspicious or
whether there is a risk of money laundering or terrorist financing:
a) Is it inconsistent with the customer’s known activities?
b) Is the size of the transaction inconsistent with the normal activities of the customer
as determined at the initial identification stage?
c) Are there any other transactions linked to the transaction in question of which the
Company is aware of and which could be designed to disguise money and divert it
into other forms of other destinations or beneficiaries?
d) Is the transaction rational for the customer?
e) Has the customer’s pattern of the transactions changed?
f) Is the customer’s proposed method of payment unusual in the context of the services
provided by the Company?