Module 3 · Chapter 7

Money Laundering Red Flags and the Internal Report

Some facts only call for closer checks. Others, taken together, add up to a suspicion. This chapter shows where that line falls, and how you report a suspicion inside the firm.

≈ 9 min read 8-question test

In this chapter

  • Which facts on this file are red flags, and when they add up to a suspicion
  • Why a suspicion needs no proof, and what the law asks of you
  • How to write the internal report, and what follows it

7.1Red flags and the internal report in one paragraph

A red flag tells you to look closer, and most are answered by closer checks. Sometimes the flags add up, and the checks cannot answer them. Then you may suspect money laundering, even with no proof. You report the suspicion in writing only to the firm’s money laundering reporting officer, and he decides what happens next.

Key point

Report a suspicion the day it forms. You need no proof, only what you saw and why it worries you.

Also in this chapter

  1. The red flags on this file
  2. Suspicion needs no proof
  3. When the client refuses the evidence
  4. Your duty to report to the MLRO
  5. Writing the internal report
  6. Your job

Preview

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