Please write a suspicious activity report on the basis of the given facts. The analysis part of the report must not exceed 0.5 pages.

The TW customer came to our attention due to the transaction monitoring alert. Mr Smith is a 25 years old US citizen, residing in the UK. Mr. Smith registered his personal and business TransferWise account for Shipping Unlimited Ltd on 09/10/2019. Shipping Unlimited Ltd was initially registered with TransferWise as offering services related to construction. Upon registration Mr. Smith also provided the companys website, which seemed to be based on a basic template with little functionality. According to the information available online Shipping Unlimited Ltd was registered in the UK 01/10/2019.

Between 09/10/2019 and 14/11/2019, Shipping Unlimited Ltd deposited approximately 184,800.00 EUR to its TransferWise account. These deposits were made from Shipping Unlimited Ltds offshore bank account with most of the funds being deposited within 2 weeks, at times making multiple deposits a day. During this time, Mr. Smith also transferred funds from Shipping Unlimited Ltds TransferWise account, usually immediately after each deposit. Between 15/10/2019 and 19/10/2019 approximately 114,900.00 EUR was transferred from the TransferWise account of Shipping Unlimited Ltd to 3 recipients. The recipient Geen Ltd received exactly 60,000.00 EUR from Shipping Unlimited Ltd. Exactly 25,000.00 EUR was sent to the recipient VegaVega Ltds Portuguese bank account. Additionally, exactly 24,500.00 EUR was transferred to the Dutch bank account of the recipient Heavyships AG.

According to the recipients websites, Heavyships AG sells heavy construction machinery, VegaVega Ltd is a Portuguese road sign manufacturer, Geen Ltd AG however offers genetic testing services.

During the investigation, on 28/11/2019 Mr. Smith was asked to provide bank statements for Shipping Unlimited Ltds offshore account and elaborate on the relationship with the recipients. Mr. Smith responded 4 days later explaining that Shipping Unlimited Ltd is a supplier of construction equipment and health sector machine providing examples: Scanners, patient monitors and aesthesia machines. Mr. Smith also provided a new website for Shipping Unlimited Ltd. When checking this website URL we found that it was created on 29/11/2019.

Mr. Smith also provided invoices supposedly issued to Shipping Unlimited Ltd by the above described recipients. These look very suspicious and brought the validity of the documents into

question. Most of the provided documents were created on 02/12/2019. For example, Mr. Smith provided two invoices dated on 11/10/2019 and 18/10/2019 respectively from Heavyships AG. One showing the purchase of X-Ray machines, the second the purchase of Untrasonography machines. No information about the type, model, serial number etc of these products added to the invoices.

Mr. Smith did not provide the bank statement for Shipping Unlimited Ltds offshore account that would detail the sender/recipient information. Mr. Smith claimed that account statements with detailed transaction information are not offered by the bank.