AMLBeneficial OwnershipComplianceMoney Laundering

Red Flag Warnings for AML pt2

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Red Flag Warnings for AML pt2

Please continue reading the remainder of our AML fed flags article. Go here for part one. Go here for part three

Trade Finance Go to top

  • Items shipped that are inconsistent with the nature of the customer’s business (e.g., a steel company that starts dealing in paper products, or an information technology company that starts dealing in bulk pharmaceuticals).
  • Customers conducting business in higher-risk jurisdictions.
  • Customers shipping items through higher-risk jurisdictions, including transit through non-cooperative countries.
  • Customers involved in potentially higher-risk activities, including activities that may be subject to export/import restrictions (e.g., equipment for military or police organizations of foreign governments, weapons, ammunition, chemical mixtures, classified defense articles, sensitive technical data, nuclear materials, precious gems, or certain natural resources such as metals, ore, and crude oil).
  • Obvious over- or under-pricing of goods and services.
  • Obvious misrepresentation of quantity or type of goods imported or exported.
    Transaction structure appears unnecessarily complex and designed to obscure the true nature of the transaction.
  • Customer requests payment of proceeds to an unrelated third party.
  • Shipment locations or description of goods not consistent with letter of credit.
  • Significantly amended letters of credit without reasonable justification or changes to the beneficiary or location of payment. Any changes in the names of parties should prompt additional OFAC review.

Privately Owned Automated Teller Machines Go to top

  • Automated teller machine (ATM) activity levels are high in comparison with other privately owned or bank-owned ATMs in comparable geographic and demographic locations.
  • Sources of currency for the ATM cannot be identified or confirmed through withdrawals from account, armored car contracts, lending arrangements, or other appropriate documentation.

Insurance Go to top

  • A customer purchases insurance products using a single, large premium payment, particularly when payment is made through unusual methods such as currency or currency equivalents.
  • A customer purchases a product that appears outside the customer’s normal range of financial wealth or estate planning needs
  • A customer borrows against the cash surrender value of permanent life insurance policies, particularly when payments are made to apparently unrelated third parties.
  • Policies are purchased that allow for the transfer of beneficial ownership interests without the knowledge and consent of the insurance issuer. This would include secondhand endowment and bearer insurance policies.
  • A customer is known to purchase several insurance products and uses the proceeds from an early policy surrender to purchase other financial assets.
  • A customer uses multiple currency equivalents (e.g., cashier’s checks and money orders) from different banks and money services businesses to make insurance policy or annuity payments.

Shell Company Activity Go to top

  • A bank is unable to obtain sufficient information or information is unavailable to positively identify originators or beneficiaries of accounts or other banking activity (using Internet, commercial database searches, or direct inquiries to a respondent bank).
  • Payments to or from the company have no stated purpose, do not reference goods or services, or identify only a contract or invoice number.
  • Goods or services, if identified, do not match profile of company provided by respondent bank or character of the financial activity; a company references remarkably dissimilar goods and services in related funds transfers; explanation given by foreign respondent bank is inconsistent with observed funds transfer activity.
  • Transacting businesses share the same address, provide only a registered agent’s address, or have other address inconsistencies.
  • Unusually large number and variety of beneficiaries are receiving funds transfers from one company.
  • Frequent involvement of multiple jurisdictions or beneficiaries located in higher-risk offshore financial centers.
  • A foreign correspondent bank exceeds the expected volume in its client profile for funds transfers, or an individual company exhibits a high volume and pattern of funds transfers that is inconsistent with its normal business activity.
  • Multiple high-value payments or transfers between shell companies with no apparent legitimate business purpose.
  • Purpose of the shell company is unknown or unclear.

Embassy, Foreign Consulate, and Foreign Mission Accounts Go to top

  • Official embassy business is conducted through personal accounts.
  • Account activity is not consistent with the purpose of the account, such as pouch activity or payable upon proper identification transactions.
  • Accounts are funded through substantial currency transactions.
  • Accounts directly fund personal expenses of foreign nationals without appropriate controls, including, but not limited to, expenses for college students.

Suspect Employees Go to top

  • Employee exhibits a lavish lifestyle that cannot be supported by his or her salary.
  • Employee fails to conform to recognized policies, procedures, and processes, particularly in private banking.
  • Employee is reluctant to take a vacation.
  • Employee overrides a hold placed on an account identified as suspicious so that transactions can occur in the account.

Other Unusual or Suspicious Customer Activity Go to top

  • Customer frequently exchanges small-dollar denominations for large-dollar denominations.
  • Customer frequently deposits currency wrapped in currency straps or currency wrapped in rubber bands that is disorganized and does not balance when counted.
  • Customer purchases a number of cashier’s checks, money orders, or traveler’s checks for large amounts under a specified threshold.
  • Customer purchases a number of open-end prepaid cards for large amounts. Purchases of prepaid cards are not commensurate with normal business activities.
  • Customer receives large and frequent deposits from online payments systems yet has no apparent online or auction business.
  • Monetary instruments deposited by mail are numbered sequentially or have unusual symbols or stamps on them.
  • Suspicious movements of funds occur from one bank to another, and then funds are moved back to the first bank.
  • Deposits are structured through multiple branches of the same bank or by groups of people who enter a single branch at the same time.
  • Currency is deposited or withdrawn in amounts just below identification or reporting thresholds.
  • Customer visits a safe deposit box or uses a safe custody account on an unusually frequent basis.
  • Safe deposit boxes or safe custody accounts opened by individuals who do not reside or work in the institution’s service area, despite the availability of such services at an institution closer to them.
  • Customer repeatedly uses a bank or branch location that is geographically distant from the customer’s home or office without sufficient business purpose.
  • Customer exhibits unusual traffic patterns in the safe deposit box area or unusual use of safe custody accounts. For example, several individuals arrive together, enter frequently, or carry bags or other containers that could conceal large amounts of currency, monetary instruments, or small valuable items.
  • Customer rents multiple safe deposit boxes to store large amounts of currency, monetary instruments, or high-value assets awaiting conversion to currency, for placement into the banking system. Similarly, a customer establishes multiple safe custody accounts to park large amounts of securities awaiting sale and conversion into currency, monetary instruments, outgoing funds transfers, or a combination thereof, for placement into the banking system.
  • Unusual use of trust funds in business transactions or other financial activity.
    Customer uses a personal account for business purposes.
  • Customer has established multiple accounts in various corporate or individual names that lack sufficient business purpose for the account complexities or appear to be an effort to hide the beneficial ownership from the bank.
  • Customer makes multiple and frequent currency deposits to various accounts that are purportedly unrelated.
  • Customer conducts large deposits and withdrawals during a short time period after opening and then subsequently closes the account or the account becomes dormant. Conversely, an account with little activity may suddenly experience large deposit and withdrawal activity.
  • Customer makes high-value transactions not commensurate with the customer’s known incomes.

Potentially Suspicious Activity That May Indicate Terrorist Financing Go to top

The following examples of potentially suspicious activity that may indicate terrorist financing are primarily based on guidance “Guidance for Financial Institutions in Detecting Terrorist Financing” provided by the FATF. FATF is an intergovernmental body whose purpose is the development and promotion of policies, both at national and international levels, to combat money laundering and terrorist financing.

  • Activity Inconsistent With the Customer’s Business
  • Funds are generated by a business owned by persons of the same origin or by a business that involves persons of the same origin from higher-risk countries (e.g., countries designated by national authorities and FATF as non-cooperative countries and territories).
  • The stated occupation of the customer is not commensurate with the type or level of activity.
  • Persons involved in currency transactions share an address or phone number, particularly when the address is also a business location or does not seem to correspond to the stated occupation (e.g., student, unemployed, or self-employed).
  • Regarding nonprofit or charitable organizations, financial transactions occur for which there appears to be no logical economic purpose or in which there appears to be no link between the stated activity of the organization and the other parties in the transaction.
  • A safe deposit box opened on behalf of a commercial entity when the business activity of the customer is unknown or such activity does not appear to justify the use of a safe deposit box.

Funds Transfers

  • Funds transfers are ordered in small amounts in an apparent effort to avoid triggering identification or reporting requirements.
  • Funds transfers do not include information on the originator, or the person on whose behalf the transaction is conducted, when the inclusion of such information would be expected.
  • Multiple personal and business accounts or the accounts of nonprofit organizations or charities are used to collect and funnel funds to a small number of foreign beneficiaries.

Read our other articles or continue the list below.

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  • Foreign exchange transactions are performed on behalf of a customer by a third party, followed by funds transfers to locations having no apparent business connection with the customer or to higher-risk countries.
  • A customer obtains a credit instrument or engages in commercial financial transactions involving the movement of funds to or from higher-risk locations when there appear to be no logical business reasons for dealing with those locations.

Other suspicious transactions

  • Transactions involving foreign currency exchanges are followed within a short time by funds transfers to higher-risk locations.
  • Multiple accounts are used to collect and funnel funds to a small number of foreign beneficiaries, both persons and businesses, particularly in higher-risk locations.

Higher risk located banks opening accounts.

  • Funds are sent or received via international transfers from or to higher-risk locations

Contact us for a FREE pdf of the full red flag list. Just put ‘Free red flag pdf’ in the comments box.

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