Recommended actions in the event of credible publications of mass fraud or ML/FT cases in the press

In the event of credible publications of mass fraud or ML/FT cases in the Belgian and/or international press, financial institutions and in particular their AMLCO should thoroughly analyse these publications and assess whether they themselves or certain customers or business relationships are affected by the fraud or ML/FT cases.

If this proves to be the case, financial institutions should take the published information into account when applying their risk-based approach (see the page Risk-based approach and overall risk assessment), in particular by updating the data or information available to them in the context of their business relationships and, where appropriate, by also carrying out a new individual risk assessment on the basis of the published information (see in particular point 2 of the page Due diligence on business relationships and occasional transactions and detection of atypical facts and transactions).

Furthermore, affected financial institutions should detect and analyse atypical facts and transactions in view of the published information (see the pages Due diligence on business relationships and occasional transactions and detection of atypical facts and transactions and Analysis of atypical facts and transactions).

Finally, where necessary, financial institutions should report (additional) suspicions to CTIF‑CFI (see the page Reporting of suspicions).

The NBB further requests financial institutions to inform it proactively and without delay of any involvement in such publications. The institutions concerned should indicate which specific actions they have taken or will take in this respect (mentioning any “lessons learnt” where appropriate). They should also notify the NBB of the results of internal investigations and analyses.