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Red Flags ( Risks )

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Red Flags (risks) implicit in the scenario
Given the outline above there are risks to be considered which are potentially suspicious or “red flags” which give rise to money laundering or terrorist financing risks, specifically;
• Funds transfer – large deposits from unconnected third parties in high risk jurisdictions and large cash deposits by the customer could indicate money laundering
• Activity inconsistent with customers business - Letter of credit for cement when the customer is a small trader (fruit and veg) – this could indicate terrorist financing (in Dec 2014 multiple press articles indicating “cement for rebuilding Gaza diverted to terror tunnels” and also presents a trade finance risk (In July 2013 the FCA issued a report on the state of the major banks control of AML risks relating to trade finance, one of the main findings was that Letters of Credit were not reviewed sufficiently reviewed (https://www.fca.org.uk/news/tr13-03-banks-control-of-financial-crime-risks-in-trade-finance))
• Lending – request for loans – possibly obscuring movement of funds
• Large cash deposits – seemingly large deposits would be strange give the nature of the business
The presence of such red flags does not necessarily indicate by itself criminal activity but certainly closer scrutiny is required to determine whether the activity is suspicious or there doesn’t appear to be reasonable business use. The primary focus should be on reporting suspicious activity, rather than

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