Lawyers and legal advisors

Recognizing unusual transactions

As a service provider (Lawyers and legal advisors), 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 – lawyers and legal advisors

  • There are reasons to doubt the origin of the title under which funds are provided to clients which are managed by the professional in question
  • The client or the intermediary is not prepared to provide information on the origin of the title of the funds or is only prepared to do so following extended, frequent pressure.
  • A request by a client to carry out various transactions, while the client’s name is not disclosed in these transactions
  • A client wishes to use the third-party funds account for a different purpose than the intended one (without any legal basis).
  • The client transferred an amount into the third-party funds account and asks that this be returned via another account/other accounts whether or not this is in the client’s name, or asks for the amount to be repaid by way of a check
  • A client requests mediation for a certain transaction for which a current contract has not been submitted or if the underlying reason for this is unclear