Revisiones impulsadas por eventos: Banderas rojas e investigaciones de blanqueo de dinero

Posted in Conozca a su cliente (KYC) on mayo 8, 2024
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Event-driven reviews. Money laundering is a criminal activity carried out by criminals or organizations of criminals. The goal is to use the country’s financial system to hide and transfer cash obtained via unlawful methods. To avoid the incidence of money laundering concerns, they must be detected and analyzed.

Event-Driven Reviews

Event-Driven Reviews: Red Flags And Investigations Of Money Laundering

All activities and transactions that are outside of typical client activity or a specified threshold should raise a «red flag» or alert, which the MLRO or AML team should assess and investigate in collaboration with other appropriate employees. MLRO must guarantee that the red flag process takes into account all conceivable risk variables, taking into account the consumers’ risk profiles.

For transaction monitoring, red alert levels are defined, and the thresholds are indicated in the automated transaction monitoring system. When thresholds are breached, or unexpected transaction/activity occurs, an alert is triggered, and the AML analyst examines the transaction/activity.

AML Team

The AML team conducts event-driven evaluations to detect and analyse the risks that consumers may bear, which might result in reputational and financial losses. Money laundering and terrorist funding are two examples of such threats. 

The identification and assessment of such risks enable the prevention of such risks. Money laundering risks may be identified during the investigation of the transactions, which are highlighted due to the trigger of red flags. Red flags must be triggered on any unusual and irregular transaction or activity for review and investigation, considering the risk of money laundering by the existing customer or any other person. Money laundering risks are considered by reviewing the existing profile of the customer to whom the particular transaction or activity relates.

During the performance of transaction monitoring, according to the defined transaction monitoring policies, controls, and procedures, the MLRO must consider the updated and current profile of the customer while assessing the risks of money laundering in the transaction or activity highlighted through the red alert mechanism. Money laundering risks are assessed considering the trend of transactions and activities of the customer concerning the changes in the business activities or landscape mentioned in the customer’s risk profile. 


MLRO or AML team must investigate the respective transactions and make inquiries of the customers and persons involved. During the monitoring and investigation process, the MLRO may consult with the lawyer regarding the possibility of the occurrence of money laundering related to a particular customer, considering the confidentiality and compliance with applicable laws and regulations. Further, appropriate negative media searches play an important part in the overall money-laundering investigation.

All such inquiries and responses must be evaluated and recorded during the assessment and evaluation of possible occurrence of risk incidents related to the corruption and bribery payments. The management must take appropriate actions according to applicable legal and regulatory frameworks when such transactions are confirmed.

Examples Of Event-Based Red Flag Trigger Points

Below are some examples of trigger points for the red flags concerning money laundering:

  • frequent cross border flow of transactions especially with high-risk countries;
  • a large amount of cash deposit in smaller portions;
  • a large amount of cash deposited in an account, at once;
  • payment received in account, not matched with goods shipped (trade-based money laundering);
  • unexpected repayment of overdue credit amount; 
  • transaction inconsistent with customer’s business profile;
  • deposit or transfer of funds, without any specific justification;
  • transactions made for significant investment;
  • a sudden increase in the number/ value of deposits or credits;
  • the sudden increase in the large deposit in the dormant accounts. 

Final Thoughts

Crime is on the rise in the modern world, and with advanced technology, fraudsters are devising new ways to carry out their malicious plans. Money laundering is one of these crimes that has long been used to exploit businesses. The traditional methods of laundering money have gone virtual. Criminals have devised sophisticated methods for concealing the source of illegally obtained funds. Financial institutions, cryptocurrency exchanges, and Fintech firms are the most vulnerable to money laundering.

Given the recent rapid increase in money laundering, all businesses anticipate an increase in the future. All countries’ regulatory authorities are working to prevent money laundering. Every company is required to follow the Financial Actions Task Force’s guidelines (FATF). These recommendations are intended to protect businesses from various types of criminal activity, particularly money laundering. Furthermore, the guidelines have identified specific acts that can assist businesses in detecting money laundering activities. FATF refers to these acts as red flags, and they aid in the identification of money laundering.