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KYC/AML for cross-border PSPs - spotting the 'new' red flags
Running a PSP, especially one touching multiple jurisdictions, the KYC/AML landscape feels like a game of whack-a-mole with new 'unusual' patterns emerging weekly. Beyond the obvious red flags, what are others seeing as the more subtle, but increasingly common, indicators of money laundering attempts? The regulators aren't exactly publishing the playbooks for the latest schemes, are they?
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The increased use of shell companies with no clear economic purpose, especially those registered in less transparent jurisdictions, seems to be a consistent subtle red flag. Also, sudden, unexplained changes in transaction patterns for established clients, even if the amounts are not immediately alarming.