Bank’s Ability to Provide Information on Shell Customers and Transactions

Jordan’s Anti-Money Laundering and Counter Terrorist Financing (AML/CTF) Regulations

Jordan’s AML/CTF regulations require banks to maintain certain standards when dealing with customers who may not have a physical presence or engage in non-face-to-face transactions. According to Article 15 of the AML/CTF Law, banks are prohibited from tipping off individuals about impending investigations.

Reporting Suspicious Activity Reports (SARs)

In cases where additional due diligence is required for non-face-to-face transactions, banks must apply necessary policies and procedures to mitigate risks. This includes reporting SARs to the Anti-Money Laundering & Counter Terrorist Financing Unit, which will determine whether to proceed with a transaction.

Reporting Authority to Proceed with Suspicious Transactions

Regarding the requirement to obtain authority to proceed with a current/ongoing transaction identified as suspicious, banks must report such transactions to the Anti-Money Laundering and Counter Terrorist Financing Unit for approval. The unit will then decide whether to allow or reject the transaction.

Data Protection Laws

While Jordan has no comprehensive Data Protection Law, the Constitution recognizes a limited right to privacy. The Personal Data Protection Act is currently being drafted, but it is not yet effective.

Restrictions on Transferring Credit Reports

Regarding restrictions on transferring credit reports, Jordan has no specific laws governing this issue.

Risk-Based Approach

The Central Bank of Jordan has approved the adoption of a risk-based approach for customer due diligence. Banks are required to use this approach when verifying the identity of customers and monitoring transactions.

Verification of Identification Documents

Banks must:

• Preview official identification documents provided by customers
• Obtain a copy signed by a competent employee
• Verify the validity of the information through reliable sources

In cases where legal persons are involved, banks must verify the existence, legal form, names of owners, and authorized signatories using necessary documents and information.

Impact on Transfer of Information

Jordan’s lack of Data Protection Laws may impact the transfer of information to this jurisdiction. While the Constitution recognizes a limited right to privacy, these rights can be circumscribed by laws to be claimed.