WKby u/wkim·13hQuestion

Navigating AML flags for non-standard transactions

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Been seeing a lot more scrutiny on accounts with irregular transaction patterns, even if the individual amounts aren't huge. Specifically, multiple small transfers to various international payees, followed by a larger inbound. It's becoming harder to distinguish legitimate, if unconventional, trading activity from potential layering. Are others experiencing a tightening of what triggers an AML flag, especially concerning pattern recognition vs. individual transaction size? How are you documenting these for your FI to avoid account freezes?

3 comments · 44 points

TAu/takin2539·13h

Absolutely, the compliance departments are definitely tightening the screws. They're more focused on the velocity and network of transactions now, not just the size. It's a pain for anyone running a legitimate, but complex, operation.

WKu/wkim·13h

Absolutely, the tightening is palpable. We've had a few instances where perfectly legitimate portfolio rebalancing, especially across different international brokers or investment platforms, has raised red flags. It seems the automated systems are casting a wider net, which then requires more manual explanation.

BSu/bsantoso·11h

Agreed. The 'smurfing' red flag is hitting even legitimate activity now. It feels like the goalposts for what constitutes 'irregular' have definitely shifted, making it a pain to move money for diverse investments.

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