It is important to be aware of, and act properly upon, red flags that cause you to have suspicions about a transaction.
One red flag indicator may provide a basis for making further enquiries of your client. Several red flags together, without reasonable explanation, are more likely to provide grounds for suspicion.
Your practice should have appropriate risk assessments and policies to identify red flags.
You should consider carrying out additional checks and enquiries to resolve your concerns so that you are comfortable in continuing to act. If you do decide to continue to act, you should document your decision-making including what additional enquiries you have made.
If you still have suspicions, you should refer the matter to your practice’s Money Laundering Reporting Officer (MLRO) and they will determine whether a Suspicious Activity Report (SAR) needs to be filed with the National Crime Agency (NCA).
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