Financial institutions' reporting obligation to the Anti-Money Laundering Authority (The Eye is on Us)

Financial institutions, such as banks, insurance companies,.
The reporting obligation of financial institutions to the Authority for the Prohibition of Money Laundering is divided into two:
Standard report, automated reporting due to the execution of specific actions, detailed below, without exercising discretion. .
Unusual report, reporting for the performance of certain actions, detailed below, at the discretion of the financial institution based on its knowledge of the customer and the customer's business transaction patterns. This refers to account activity that there is reason to believe is related to money laundering or terrorist financing. Even if there is no knowledge or suspicion of a connection between the activity and a crime.

Activities Requiring Regular Reporting:

1. Depositing cash into or withdrawing cash from a bank account exceeding NIS 50,000. .
2. A cash transaction not carried out through any customer account, including a cash deposit for the purpose of transferring funds abroad or a cash withdrawal received from abroad, not through an account, whether in Israeli currency or foreign currency, in an amount equivalent to at least NIS 50,000, and also a cash deposit or cash withdrawal as aforesaid in an amount equivalent to at least NIS 5,000, which is made with a financial institution in a country not listed in the list detailed in the law.
3. Depositing checks and/or paying checks of a financial institution outside of Israel in an amount equivalent to NIS 1,000,000. If the country is not on the list specified in the law, then a reporting obligation shall apply starting from NIS 5,000.
4. Check discounting for cash by a currency service provider (change)  In a sum of at least 50,000.
5. Transfer from Israel to abroad or from abroad to Israel, via bank account, in an amount equivalent to NIS 1,000,000 or more.
6. To issue a bank check, in Israeli currency/foreign currency, for an amount of at least NIS 200,000; except for a bank check in an amount up to NIS 1,000,000, issued against a housing loan.
7. Purchase or sale of traveler's checks exceeding 50,000 NIS.

Actions Requiring Unusual Reporting:

1. Activity in an account in an amount close to the amount required for regular reporting, as mentioned above (which appears to be intended to circumvent the regular reporting obligation).
2. That the account holder appears to the financial institution to be managing the account for someone else (a straw man) without having declared it.
3. An activity that appears to be intended to replace the activity of a person declared a terrorist.
4. An activity that appears to lack business or economic logic, with reference to the type of bank account or the customer's behavior patterns.;
5. A significant bank account transaction conducted by a power of attorney holder who is not listed on the account as an authorized signatory;
6. A number of bank account transactions where, for no apparent reason, funds and securities are withdrawn shortly after being deposited, not as part of the usual course of business;
7. Transfer of a substantial amount from abroad to the country and vice versa, where the other party to the transaction, the source or destination, is not identified by name or account number;
8. The transaction on the account is uncharacteristic for the account holder or the type of bank account.;
9. Unusual transaction activity or a significant change in bank account balance.;
10. Multiple transactions in a bank account to the same destination or from the same source;
11. Multiple deposits, for no apparent reason, by an unauthorized individual or non-signatory.;
12. Non-presentation for payment of a bank check in a substantial amount more than 12 months after its issuance.;
13. Managing multiple accounts in a banking corporation that are inconsistent with the client's activity;
14. Acquisition of cash, traveler's checks, bearer checks, or other payment methods, not through a bank account, frequently;
15. Ongoing transfers to non-cooperating countries in the war on money laundering, meaning countries not listed in the law, and transfers to them;
16. Multiple credit entries from standing orders to a bank account for no apparent reason.;
17.  A credit to a debit card account or multiple credits, all in a substantial amount, with no apparent reason.