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guarantors, suppliers of leased goods or persons unrelated to the business relationship in question who intervene spontaneously and cover the exposure in the event of the debtor defaulting;

transactions carried out by agents, which, in view of their frequency and amount, cannot be linked to the economic activity or the characteristics of the principal.

1.7 Transactions requested with obviously inexact or incomplete details, suggesting the intention of hiding essential information, especially if this concerns parties interested in the transaction;

1.8 Transactions involving counterparties located in offshore centres or geographical areas well known for drug running or tobacco smuggling that are not justified by the economic activity of the customer or other circumstances.

2. Anomaly indicators for transactions in cash or e-money

2.1 Withdrawals of large amounts of cash except where the customer has special needs.

2.2 Deposits of large amounts of cash that cannot be justified by the customer’s economic activity.

2.3 Use of cash instead of the means of payment normally used by the customer:

frequent requests for large cashier’s checks against payment in cash instead of being charged to the customer’s account;

frequent use of large sums of cash to make transfers within a short lapse of time, especially where the counterparties are located abroad;

large and/or frequent payments of insurance premiums in cash without apparent justification, especially in the case of multiple policies;

large payments in cash in settlement of amounts due following the use of credit cards, especially if these have no spending limits.

2.4 Exchange of banknotes for others of different denominations and/or for foreign currency, especially where the transactions are not channeled through a current account:

exchange of banknotes for significant amounts, either in one shot or at short intervals, especially in the case of high-denomination notes;

exchange of lira or other EU banknotes for other foreign currencies in the run-up to the introduction of the euro, especially if at frequent intervals and for large amounts;

exchange of lira or other EU banknotes for euros in the run-up to the introduction of the euro, especially if at frequent intervals and for large amounts.

2.5 Transactions involving the use of e-money, which, in view of their size or frequency, are not consistent with the activity of the distributor or merchant or with customers’ normal use of e-money:

excessive requests for e-money or repeated requests for the reimbursement of the unspent value of e-money by individual distributors;

anomalous sales volumes with respect to an individual merchant’s type of activity;

frequent or large (even if split up) requests by customers for the reimbursement of amounts concerning unused e-money credits.

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