Articles Posted in Money Laundering

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Money Laundering “Red Flags”

Questions to ask and

Things to be alert and mindful of….

  • Beneficial owners are in the “background” and you are, or should be, aware
  • Buyer and property are a mis-match
  • Buyer’s agent responses do not meet your due diligence requirements
  • Buyer’s income is inadequate to pay an 80% financed deal
  • Cash Deal? (remember: if there is a mortgage the lender always asks for a AML letter)
  • Client asks to use a Third Person nominee
  • Client is vague and reluctant to reveal the “person of interest” in the transaction
  • Deposits come from more than three banks
  • Income sources go back less than three years
  • Know Your Client: it’s the law!
  • Money Broker is involved
  • Money coming in from three sources and/or payment amounts (in dollars) are similar
  • Money instruments are used for any cost or payment
  • Non customary agents, payees, or persons appear on or at the closing
  • Notarized documents are not U.S.A. in origin
  • Off record payments or things of value are exchanged between parties
  • Payments of any kind are from more than three individuals or sources
  • Purchase is made without viewing the property or without inspection
  • Re-sold at the closing
  • Residential property is titled in a third person party
  • Rushed purchases or rushed sales
  • Sale price is high or low by a significant amount or percentage
  • SAR? Know what it is and who can and does make them…
  • Structuring? Be familiar with what structuring can look like
  • Third party names appear on monetary instruments
  • Transaction costs are unusual and the buyer doesn’t care
  • Trust but verify
  • Trust is the buyer and the Trustee is a non-U.S.A. resident
  • Vague or minimal information about a party participating in the transaction
  • Willful Blindness? Know what it is…..
  • Witnesses on documents are not U.S.A. residents