2. Criteria for revealing and features of doubtful non-trading operations.

2.1. The Department can render a non-trading operation doubtful in case:

• of revealing transfers misuses without performing trading operations on the account;
• of revealing unusual nature of operations, that don’t have obvious economic substance or obvious legal purpose;
• of revealing circumstances implying that the operations are performed for the purpose of money laundering or terrorist financing;
• the Customer doesn’t provide data for his identification, submits unreliable data and/or it is impossible to contact the Customer at the indicated addresses and telephone numbers;
• the Customer doesn’t provide data for the identification of the beneficiary, i.e. a person to the advantage of whom the Customer acts (in particular, on the basis of an agency contract, commission and trust management contracts, while performing non-trading operations);
• of submitting false or invalid documents;
• at the location of a juridical person there is no regulatory body or another body or person, that has the right to act on behalf of the juridical person without power of attorney.

2.2. The specified operations shall be revealed by subjective estimation of the employees of the Department by means of daily analysis of non-trading operations.

2.3. The criteria for revealing and features of doubtful non-trading operations specified in clause 2.1. shall not be mandatory or comprehensive.

The Department can render a non-trading operation doubtful on the basis of analysis of the nature of a non-trading operation, its components, attending circumstances and interaction with the Customer or his representative.

2.4. In case of revealing doubtful non-trading operations the Department shall take a decision in its sole discretion in relation to further actions in regard to the Customer and his non-trading operations.