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4.5 Large and/or simultaneous requests to cash in several insurance policies and/or their use to obtain loans, especially where this involves accepting disadvantageous conditions, or frequent partial cashings in of large single-premium policies.

4.6 In the case of payment of large premiums, exercise of the right of revocation or withdrawal referred to in Articles 111 and 112 of Legislative Decree 174/1995.

4.7 Conclusion of a capitalization scheme contract with the delivery by the contracting party of securities or other assets (see Article 40 of Legislative Decree 174/1995) whose possession is not justified by the party’s income-earning capacity and type of business.

5. Anomaly indicators for transactions involving other products and services

5.1 Presentation of outstanding bearer bank or Post Office deposit books with a balance above the legal limit, without the customer providing an adequate explanation of the late presentation.

5.2 Use of letters of credit and other trade finance techniques to transfer amounts between countries, without the related transaction being justified by the customer’s usual economic activity.

5.3 Fiduciary registration of goods and/or financial instruments where they have been in the customer’s possession for only a short time and it does not appear justified in the light of the customer’s wealth or activity.

5.4 Repeated use of safe deposit boxes or custody services or repeated deposits and withdrawals of sealed packages not justified by the customer’s activity or habits.

5.5 Issue of mandates to access safe deposit boxes to persons outside the family circle or not linked by relationships of collaboration or of other kinds that would justify their issue.

5.6 Purchase or sale of large quantities of coins, precious metals or other valuables for no apparent reason or not congruous with the customer’s economic situation.

5.7 Accounts that show a volume of transactions that is not justified by the customer’s activity or that are marked by: frequent inpayments of checks or securities to be discounted, especially if in round figures, with a plurality of endorsements and other recurrent features or issued to bearer or to the same drawer; withdrawal of bills and return of unpaid items, possibly followed by protest; substantial balance of credits and debits.

6. Anomaly indicators for customer behaviour

6.1 Customers who refuse or are reluctant to provide the information needed to carry out transactions, to specify their activity, to present accounting or other documentation, to declare accounts held with other intermediaries, to give information which, in normal circumstances, would make the customer a fit person to carry out banking, financial or insurance transactions.

6.2 Customers who ask to restructure a transaction where, as originally set up, it would have involved identification or registration or additional inquiries by the intermediary.

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