To report unusual transactions the reporting institutions makes use of indicators. Pursuant to article 10 of the NORUT, these indicators are described in the Ministerial Decree Indicators for Unusual Transactions. In this decree, a distinction can be made between objective indicators and subjective indicators.
An objective indicator encompasses a limit amount or describe a particular situation that qualifies the transaction in question as unusual in all cases.
Hereafter you’ll find a couple of examples of objective indicators for different institutions:
- - Banks: Cash transactions of or above NAF 25.000,- should be reported.
- Gaming institutions: Cash depots of or above NAF 5.000,-
- Non-financial businesses and professions: Cash transactions of or above NAF 25.000,-
A subjective indicator requires the skills of the service provider. On the basis of his knowledge, experience and insight, he qualifies a transaction as unusual if the transaction conducted or proposed is atypical for the client concerned, i.e. does not fit the client’s profile.
Here you’ll find a couple of examples of subjective indicators for different institutions:
- - Banks: The client makes use of forged or fake documents.
- Gaming institutions: Transactions where the client purposely stays under the NAF 5.000,- threshold
to prevent the reporting of the transaction.
- Non-financial businesses and professions: Frequent changes in legal structures and/or in
managing directors of legal entities/companies.
A list of the specific objective or subjective indicators per type of institution can be downloaded here: Indicator listing
When reporting an unusual transaction to the FIU, the appropriate indicator must be mentioned.