Recognising crime—red flags and warning signs for staff

The following Risk & Compliance precedent provides comprehensive and up to date legal information covering:

  • Recognising crime—red flags and warning signs for staff

Recognising crime—red flags and warning signs for staff

You do not have to behave like a police officer but you do have to remain alert to the red flags and warning signs of crime taking place in our organisation and make the sort of enquiries that a reasonable person (with the same qualifications, knowledge and experience as you) would make.

This awareness tool identifies typical red flags and warning signs that may indicate that our organisation is involved in or is itself being used to commit crime (eg money laundering, terrorist financing, bribery, corruption, fraud or organised crime). These factors do not automatically mean that crime is taking place, but you should be aware of them and pay particular attention to matters where a number of factors are present. These red flags and warning signs would normally require further investigation.

Methods for committing crime change all the time. We have set out below typical general red flags and warning signs, broken down into three categories: (1) the customer, (2) the money, and (3) the transaction/instructions. The lists are not exhaustive.

    1. 1

      The customer

      Red flags and warning signs in relation to the customer include where the customer:

      —is excessively obstructive or secretive;

      —is a politically exposed person (PEP);

      —uses an intermediary, or does not appear to be directing the transaction, or appears to be disguising the real customer;

      —avoids personal contact without good

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