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Starting August 9, Uzbekistan will enforce amendments to internal control regulations for commercial banks. The Ministry of Justice registered the relevant decision by the Central Bank Board and the Department for Combating Economic Crimes under the Prosecutor General's Office on May 8.

Key changes include raising the limit for purchasing foreign cash without mandatory client verification from $100 to $500. The threshold for verifying transactions conducted without opening a bank account has been lowered to 175 million soums. New requirements for information on senders and recipients of money transfers have been introduced.

For transactions without opening or using a bank account, the threshold for mandatory client verification has been reduced. Previously, verification was required for amounts exceeding 500 times the base calculation value (BCV) — 206 million soums. The new fixed threshold is 175 million soums, aligning with FATF Recommendation 10.

Requirements for information on transfer senders and recipients have been expanded. Sender data includes full name, address, TIN or client identification number, account number, or unique transaction code. For individuals, passport or ID card details, date of birth, and place of residence are also required. Recipient data includes name, country, city, TIN or identification number, account number, or unique code.

The threshold for providing expanded information on domestic electronic payments and transfers has been reduced from 30 to 25 times the BCV (10.3 million soums). This aligns with FATF recommendations allowing a minimum threshold of $1,000 (approximately 12.2 million soums).

New criteria for suspicious transactions have been introduced. Receipts, transfers, or cash withdrawals exceeding 40 times the BCV (16.48 million soums) within two business days from the account of an individual under 16 years old are deemed suspicious. The Central Bank notes that minors cannot make independent financial decisions, and large turnovers may indicate the use of "nominal" accounts.

Transactions involving funds received from or sent to countries under FATF enhanced monitoring are now considered suspicious if the total amount exceeds 1,000 BCV (412 million soums) in a single operation or within 30 days.

The threshold for classifying transactions related to changes in import contract subject as suspicious has been lowered from 20,000 BCV (8.24 billion soums) to 5,000 BCV (2.06 billion soums). The initial proposal suggested 3,000 BCV.

A procedure for comprehensive analysis of suspicious transactions without quantitative thresholds has been introduced. After notifying the authorized state body, banks must collect and analyze information on transaction participants within 10 business days, including assessing business reputation, sources of funds, transaction structure, timing, volume, and geography.

Banks must evaluate whether the transaction matches the client's usual business activities and financial profile, analyze relationships between participants, including affiliation, control, or other forms of mutual control. Complex or multi-step transaction chains aimed at concealing the beneficial owner, source of funds, or true purpose are also examined.

If conducting a verification could lead to information disclosure to the client, the bank has the right to immediately report the suspicious transaction to the authorized body without verification.

The concept of batch transfers has been introduced and regulated. These are operations combining multiple payments to a single financial institution, which may be made in favor of one or several recipients.

Source: www.gazeta.uz