Recognising crime—red flags and warning signs for staff—law firms

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

  • Recognising crime—red flags and warning signs for staff—law firms

Recognising crime—red flags and warning signs for staff—law firms

You must remain alert to the red flags and warning signs of crime potentially taking place in our organisation. While you do not have to behave like a police officer, you must 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 firm is involved in or is itself being used to commit crime (eg money laundering, terrorist financing, bribery, corruption, property or mortgage 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 client, (2) the money, (3) the transaction and then signs to look out for in specific areas of work. The lists are not exhaustive.

    1. 1

      The client

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

      —is excessively obstructive or secretive;

      —is a politically exposed person (PEP);

      —uses an intermediary, or does not appear to be

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