Trust service provider

Recognizing unusual transactions

As a service provider (Trust service provider), 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 – Trust service provider

  • A transfer from the account in the name of the company managed by the trust service provider into the account of the proxy, which funds are then withdrawn in cash by said proxy
  • Payments are made via a company account managed by the trust service provider to other companies (whether or not these are abroad), without any agreement or accounts forming the basis for this
  • Unclear relationship between a potential ultimate beneficial owner and signatories
  • An inexplicable geographical link between the trust service provider and the client’s location
  • The structure of the client’s company makes it difficult to ascertain who the ultimate beneficial owner is



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