Recognizing unusual transactions

As a service provider (Bank), you are aware of the practices in your industry. Determining whether a transaction is classified as unusual depends, to a great extent, on your professional opinion. Your opinion corresponds with what is considered unusual within your profession. In addition to your opinion, there are circumstances of an unusual nature which must therefore be reported.


If one of the scenarios described in the general examples below (which are not exhaustive) arises, then this is cause to further examine whether the transaction could be connected with money laundering and/or terrorist financing.
If you suspect activities of money laundering or terrorist financing, then you must report it.

Red flags – Bank

  • A transaction in small cash denominations, with uncounted cash, in unusual packaging;
  • Frequent deposits by someone besides the account holder, which is inappropriate for the client’s profession or work;
  • The client is nervous for no valid reason;
  • The turnover on the account stands out, as it is not in proportion to the client’s profession, work or business activities;
  • Incoming payments, sourced from typical offshore financial centers;
  • Outgoing payments to parties/countries which do not match the client’s profile.