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Recognising Money Laundering - Red Flags (The receipt of unusually large…
Recognising Money Laundering - Red Flags
The receipt of unusually large cash deposits
The receipt of funds followed by an immediate request for these to be paid away elsewhere
The use of multiple transfer requests where a single payment could have been sent. This could indicate an intention to avoid mandatory reporting limits that exist in some jurisdictions. Similarly the receipt of multiple receipts for no apparent reason could indicate money laundering
A reluctance to receive payments directly
Requests for third party payments or receipts without sufficient explanation - particularly where it is known to the CSP that the funds will eventually reach their client
Use of multiple bank accounts or corporate entities that do not appear to serve a purpose. These can complicate a structure unnecessarily
The use of dummy settlors
The use of blind trusts. There are legitimate uses for these however the reason for their use should be understood and be reasonable
A client whose internet profile has adverse public information involving financial or other relevant crime
A reluctance to provide usual due diligence information and a client who is reluctant for you to have direct contact with them
A client whose internet profile has adverse public information involving financial or other relevant crime
A lack of commercial rationale for the structure
A lack of legal or tax advice where the structure appears to be very complex and involving multiple entities or jurisdictions
The matching of payments requests to credits received on the same or previous day with no reasonable explanation
The use of previously dormant accounts
Unexpected early repayment of loans where the customer's means to do is not apparent
The use of a safe deposit box without reason cause
Dealings with parties located in known drug trafficking areas or countries associated with known terrorist organisations
The purchase of insurance products together with subsequently early surrender or cancellation with no concern over surrender values
A lack of concern on the behalf of the client over the cost of transactions and no interest in minimising cost
A lack of a desire to receive reports of the performance of their investments or bank account balances