Red-flag indicator library
A red-flag indicator is a published, attributable observation that a transaction warrants further enquiry. This library holds 88, each attributed to the advisory or typology report it comes from.
- indicators
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88
- issuing authorities
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6
- machine readable
- spreadsheet
Every indicator here is quoted or closely paraphrased from a named published document, with the issuing authority, the year and a link to the source. Nothing in this table is this site's own invention.
These are recognition aids, not tests. Almost every indicator has an innocent explanation available, and any one of them standing alone usually means nothing. Their value is cumulative and contextual. Treating a single indicator as proof is the characteristic error of amateur analysis in this field.
Indicators
88 listed001 A trade entity is registered at what looks like a mass registration address — a post-box, a high-density residential building or a commercial complex with no specific unit given. FATF, 2021
“registered at an address that is likely to be a mass registration address”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. a front company, shell company layering, a professional enabler
002 A newly formed or recently reactivated trade entity suddenly engages in high-volume, high-value trade, in a sector with high barriers to entry. FATF, 2021
“newly formed or recently re-activated trade entity engages in high-volume”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. a front company, a phantom shipment, trade misinvoicing
003 Owners or senior managers appear to be nominees concealing the actual beneficial owners: they lack business management experience, lack knowledge of transaction details, or manage multiple companies. FATF, 2021
“appear to be nominees acting to conceal the actual beneficial owners”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. nominee directors and nominee shareholders, a professional enabler, shell company layering
004 The entity's trade activity is inconsistent with its stated line of business — a car dealer exporting clothing, or a precious metals dealer importing seafood. FATF, 2021
“trade activity is inconsistent with the stated line of business”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. a front company, trade misinvoicing, third-country bank accounts and how are they used
005 The corporate structure is unusually complex and illogical, involving shell companies or companies registered in high-risk jurisdictions. FATF, 2021
“corporate structure of a trade entity appears unusually complex and illogical”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. shell company layering, ownership threshold structuring, a professional enabler
006 Shareholders or directors are formal nominees whose nominator is undisclosed, or informal nominees such as close associates and family. FATF, 2018
“informal nominee shareholders and directors, such as close associates and family”
Source. FATF and Egmont Group, Concealment of Beneficial Ownership (2018). Read the source document.
Appears on. nominee directors and nominee shareholders, ownership threshold structuring, a front company
007 Control over the assets is exercised through third parties — professional intermediaries, family members, associates or nominees — rather than through recorded ownership. FATF, 2018
“control can also be exerted via third parties”
Source. FATF and Egmont Group, Concealment of Beneficial Ownership (2018). Read the source document.
Appears on. nominee directors and nominee shareholders, ownership threshold structuring, shell company layering
008 A jurisdiction permits companies to act as directors without restriction, so no natural person need appear in the filings at all. FATF, 2018
“unrestricted use of legal persons as directors”
Source. FATF and Egmont Group, Concealment of Beneficial Ownership (2018). Read the source document.
Appears on. nominee directors and nominee shareholders, a professional enabler
009 The entity has no online presence, or a website whose content is boilerplate taken from other sites and shows no knowledge of the product or industry it trades in. FATF, 2021
“lacks an online presence”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. a front company, shell company layering, a phantom shipment
010 The entity shows unexplained periods of dormancy, or is not compliant with routine business obligations such as filing VAT returns. FATF, 2021
“unexplained periods of dormancy”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. a front company, shell company layering
011 The entity maintains a minimal number of working staff, inconsistent with the volume of commodities it trades. FATF, 2021
“maintains a minimal number of working staff”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. a front company, trade misinvoicing, a phantom shipment
012 Assets are distributed across multiple companies in multiple jurisdictions, so value passes through several layers of shell companies before reaching its destination. FATF, 2018
“shell companies can be used in complex structures”
Source. FATF and Egmont Group, Concealment of Beneficial Ownership (2018). Read the source document.
Appears on. a front company, shell company layering, nominee directors and nominee shareholders
013 The customer has little or no business background. BIS, 2025
“customer has little or no business background”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. a front company, dual-use re-export diversion, end-user certificate fraud
014 A foreign party to the transaction has one or more owners that are listed on the Entity List or the Military End User List. BIS, 2025
“one or more owners that are listed on the entity list”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. ownership threshold structuring, a front company, dual-use re-export diversion
015 A newly acquired foreign subsidiary continues operating its own transaction, export or customer-screening systems rather than being brought onto the parent's, with no date set for connecting the two. OFAC, 2019
“compliance functions should also be integrated into the merger, acquisition, and integration process”
Source. OFAC, A Framework for OFAC Compliance Commitments (2019). Read the source document.
Appears on. How do gaps in acquisition integration create sanctions exposure
016 A foreign subsidiary or affiliate of a US company approves, signs off on, or otherwise facilitates a transaction with a sanctioned country, region or person, on the assumption that its non-US status puts it outside OFAC's reach. OFAC, 2019
“facilitating transactions by non-u.s. persons”
Source. OFAC, A Framework for OFAC Compliance Commitments (2019). Read the source document.
Appears on. How do gaps in acquisition integration create sanctions exposure
017 No post-acquisition audit or testing has been performed to check whether an acquired entity's transactions comply with sanctions rules, so any issues that predate or survive the deal remain undiscovered. OFAC, 2019
“audit and testing function will be critical to identifying any additional sanctions-related issues”
Source. OFAC, A Framework for OFAC Compliance Commitments (2019). Read the source document.
Appears on. How do gaps in acquisition integration create sanctions exposure
018 Invoices or other trade documents show fees or prices out of line with commercial considerations, inconsistent with market value, or fluctuating sharply from comparable past transactions. FATF, 2021
“inconsistent with market value”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. trade misinvoicing, HS code misclassification
019 There are inconsistencies across contracts, invoices and other trade documents — contradictory party names, differing prices, or discrepancies in the quantity, quality, volume or value of the commodities against their descriptions. FATF, 2021
“inconsistencies across contracts, invoices or other trade documents”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. trade misinvoicing, a phantom shipment
020 The value of an entity's registered imports does not match the volume of its foreign bank transfers for imports, or its registered exports do not match incoming foreign transfers. FATF, 2021
“volume of foreign bank transfers”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. trade misinvoicing, a phantom shipment, How is correspondent banking used to evade sanctions
021 Trade documents describe the commodity only generically or non-specifically, in terms too vague to classify or value it. FATF, 2021
“vague descriptions of the traded commodities”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. HS code misclassification, trade misinvoicing
022 Trade or customs documents are missing, appear to be counterfeit, contain false or misleading information, resubmit previously rejected documents, or are frequently modified or amended. FATF, 2021
“appear to be counterfeits”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. HS code misclassification, trade misinvoicing, cargo origin blending
023 Commodities imported under a temporary importation or inward processing regime are subsequently exported with falsified documents. FATF, 2021
“temporary importation and inward processing”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. HS code misclassification, third-country transshipment, cargo origin blending
024 Payment for imported commodities is made by an entity other than the consignee with no clear economic reason — for instance by a shell or front company not party to the trade. FATF, 2021
“payment for imported commodities is made by an entity other than the consignee”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. trade misinvoicing, third-country bank accounts and how are they used, How is correspondent banking used to evade sanctions
025 Shipments are routed through a number of jurisdictions without economic or commercial justification. FATF, 2021
“routed through a number of jurisdictions without economic or commercial justification”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. third-country transshipment, dual-use re-export diversion, cargo origin blending
026 Contracts supporting complex or regular trade are unusually simple, following a sample contract structure available on the internet. FATF, 2021
“follow a “sample contract” structure”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. trade misinvoicing, a phantom shipment, a professional enabler
027 The product's capabilities do not fit the buyer's line of business — the example given is a small bakery ordering several sophisticated lasers. BIS, 2025
“capabilities do not fit the buyer's line of business”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. dual-use re-export diversion, end-user certificate fraud, How are aircraft parts procured in breach of sanctions
028 The customer or purchasing agent is reluctant to offer information about the end use of a product. BIS, 2025
“reluctant to offer information about the end-use”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. end-user certificate fraud, dual-use re-export diversion
029 The product ordered is incompatible with the technical level of the country it is being shipped to — semiconductor manufacturing equipment to a country with no electronics industry. BIS, 2025
“incompatible with the technical level of the country”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. dual-use re-export diversion, third-country transshipment
030 Routine installation, training or maintenance services are declined by the customer. BIS, 2025
“installation, training or maintenance services are declined”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. end-user certificate fraud, How are aircraft parts procured in breach of sanctions, dual-use re-export diversion
031 A freight forwarding firm is listed as the product's final destination. BIS, 2025
“freight forwarding firm is listed as the product's final destination”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. end-user certificate fraud, third-country transshipment, a professional enabler
032 The customer is willing to pay cash for a very expensive item when the terms of sale call for financing. BIS, 2025
“willing to pay cash for a very expensive item”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. dual-use re-export diversion, How are aircraft parts procured in breach of sanctions
033 Packaging is inconsistent with the stated method of shipment or the stated destination. BIS, 2025
“packaging is inconsistent with the stated method of shipment”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. dual-use re-export diversion, a phantom shipment, end-user certificate fraud
034 The buyer, when questioned, is evasive or unclear about whether the product is for domestic use, export or re-export. BIS, 2025
“evasive or unclear about whether the purchased product is for domestic use”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. end-user certificate fraud, dual-use re-export diversion, How are aircraft parts procured in breach of sanctions
035 The shipping route is abnormal for the product and the destination. BIS, 2025
“shipping route is abnormal for the product and destination”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. third-country transshipment, dual-use re-export diversion, HS code misclassification
036 The customer is unfamiliar with the product's performance characteristics but still wants the product. BIS, 2025
“unfamiliar with the product's performance characteristics”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. dual-use re-export diversion, end-user certificate fraud
037 Delivery dates are vague, or deliveries are planned for out-of-the-way destinations. BIS, 2025
“delivery dates are vague”
Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.
Appears on. a phantom shipment, third-country transshipment, end-user certificate fraud
038 An entity purchases commodities allegedly on its own account, but the purchases clearly exceed its economic capabilities and are financed by sudden cash deposits or third-party transfers. FATF, 2021
“purchases clearly exceed the economic capabilities”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. trade misinvoicing, a front company, a phantom shipment
039 A trade entity consistently shows unreasonably low profit margins — importing wholesale commodities at or above retail value, or reselling at or below purchase price. FATF, 2021
“unreasonably low profit margins”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. trade misinvoicing, HS code misclassification
040 The entity engages in complex trade deals involving numerous third-party intermediaries in incongruent lines of business. FATF, 2021
“intermediaries in incongruent lines of business”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. third-country transshipment, a professional enabler, shell company layering
041 AIS data is manipulated so that a ship broadcasts a different name, IMO number, MMSI or other identifying information — a practice referred to as spoofing. OFAC, 2020
“manipulating ais data”
Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.
Appears on. AIS manipulation and AIS spoofing, a ship-to-ship transfer
042 Transmitted AIS patterns or data are inconsistent with the ship's actual location. OFAC, 2023
“irregular ais patterns or data that are inconsistent with actual ship locations”
Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.
Appears on. AIS manipulation and AIS spoofing, flag hopping, a ship-to-ship transfer
043 Ship-to-ship transfers are conducted at night or in areas assessed as high risk for sanctions evasion, concealing the origin or destination of the cargo. OFAC, 2020
“ship-to-ship (sts) transfers”
Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.
Appears on. a ship-to-ship transfer, cargo origin blending, AIS manipulation and AIS spoofing
044 A ship-to-ship transfer conceals the origin or destination of cargo rather than serving an operational purpose. OFAC, 2019
“sts transfers can conceal the origin or destination of cargo”
Source. OFAC, Syria Shipping Advisory (2019). Read the source document.
Appears on. a ship-to-ship transfer, cargo origin blending
045 A vessel repeatedly registers with new flag states — flag hopping — or falsifies its flag outright to mask illicit trade. OFAC, 2020
“false flags and flag hopping”
Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.
Appears on. flag hopping, opaque marine insurance, a ship-to-ship transfer
046 A ship has undergone numerous administrative changes, such as repeated re-flagging. OFAC, 2023
“numerous administrative changes”
Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.
Appears on. flag hopping, opaque marine insurance, shell company layering
047 Vessel names and IMO numbers have been painted over with alternate ones so the ship can pass itself off as a different vessel. OFAC, 2018
“painting over vessel names and imo numbers with alternate ones”
Source. OFAC, North Korea Vessel Advisory (2018). Read the source document.
Appears on. flag hopping, AIS manipulation and AIS spoofing, a ship-to-ship transfer
048 A vessel physically alters the identification it is required to display on its hull or superstructure. OFAC, 2018
“physically altering vessel identification”
Source. OFAC, North Korea Vessel Advisory (2018). Read the source document.
Appears on. AIS manipulation and AIS spoofing, flag hopping
049 Shipping documentation for petrochemicals, petroleum, metals or sand has been falsified in order to disguise the cargo's origin. OFAC, 2020
“in order to disguise their origin”
Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.
Appears on. cargo origin blending, trade misinvoicing, third-country transshipment
050 A ship relies on unknown, untested, sporadic or fraudulent insurance, without which it could not meet the costs of an accident or spill. OFAC, 2023
“unknown, untested, sporadic, or fraudulent insurance”
Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.
Appears on. opaque marine insurance, flag hopping, price cap attestation fraud
051 An insurer's financial soundness, track record, regulatory record or ownership structure cannot be established on review. OFAC, 2023
“financial soundness, track record, regulatory record”
Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.
Appears on. opaque marine insurance, price cap attestation fraud
052 Shipping and ancillary costs such as freight, customs and insurance are inflated or bundled, concealing the price actually paid for the oil. OFAC, 2023
“inflation of shipping and ancillary costs”
Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.
Appears on. price cap attestation fraud, trade misinvoicing, opaque marine insurance
053 A counterparty will not provide an itemised breakdown of all costs from which the price paid for the oil could be determined. OFAC, 2023
“itemized breakdown of all costs”
Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.
Appears on. price cap attestation fraud, trade misinvoicing
054 Intermediary companies such as managers, traders or brokerages conceal their beneficial ownership or otherwise engage in unusually opaque practices. OFAC, 2023
“conceal their beneficial ownership”
Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.
Appears on. flag hopping, shell company layering, opaque marine insurance, a front company
055 A vessel navigates suspicious deviations in route — changes with no legitimate reason to go off-route, such as unsafe ports, extreme weather or emergencies. OFAC, 2020
“suspicious deviations in routes”
Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.
Appears on. AIS manipulation and AIS spoofing, a ship-to-ship transfer, cargo origin blending
056 Malign actors disguise the ultimate origin or destination of cargo by indirect routing, unscheduled detours, or transit through third countries. OFAC, 2020
“voyage irregularities”
Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.
Appears on. AIS manipulation and AIS spoofing, a phantom shipment, cargo origin blending
057 Bills of lading alleging oil, petrochemicals, fuel or metals from areas assessed as high risk for sanctions evasion are presented without further scrutiny of the cargo's origin. OFAC, 2020
“reviewing bills of lading to confirm origin of the cargo”
Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.
Appears on. cargo origin blending, trade misinvoicing, a phantom shipment
058 AIS is disabled for periods inconsistent with the safety convention that requires it to be transmitted. OFAC, 2019
“disabling automatic identification system”
Source. OFAC, Syria Shipping Advisory (2019). Read the source document.
Appears on. AIS manipulation and AIS spoofing, a ship-to-ship transfer
059 A respondent provides correspondent banking services onward to other institutions — a downstream, or nested, arrangement — so the correspondent serves customers it never onboarded. Wolfsberg Group, 2022
“downstream fi (also referred to as “nested”)”
Source. The Wolfsberg Group, Wolfsberg Financial Crime Principles for Correspondent Banking (2022). Read the source document.
Appears on. How is correspondent banking used to evade sanctions, third-country bank accounts and how are they used
060 It cannot be determined whether the respondent has controls in place to ensure payment transparency in the services it offers onward. Wolfsberg Group, 2022
“controls are in place to ensure payment transparency”
Source. The Wolfsberg Group, Wolfsberg Financial Crime Principles for Correspondent Banking (2022). Read the source document.
Appears on. How is correspondent banking used to evade sanctions, third-country bank accounts and how are they used
061 An account functions as a pay-through or transit account: rapid movement of high-volume transactions with a small end-of-day balance and no clear business reason. FATF, 2021
“rapid movement of high-volume transactions”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. third-country bank accounts and how are they used, shell company layering, hawala and how does informal value transfer work
062 Incoming wire transfers to a trade-related account are split and forwarded to unrelated accounts with little or no connection to commercial activity. FATF, 2021
“forwarded to non- related multiple accounts”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. third-country bank accounts and how are they used, How is correspondent banking used to evade sanctions, trade misinvoicing
063 Payments are routed in a circle: funds sent from one country and received back in the same country after passing through others. FATF, 2021
“payments are routed in a circle”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. third-country bank accounts and how are they used, hawala and how does informal value transfer work, trade misinvoicing
064 Very late changes are made to payment arrangements — payment redirected to a previously unknown entity at the last moment, or changes to the scheduled date or amount. FATF, 2021
“very late changes to payment arrangements”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. trade misinvoicing, third-country bank accounts and how are they used, How is correspondent banking used to evade sanctions
065 An account shows frequent cash deposits subsequently transferred to persons or entities in free trade zones or offshore jurisdictions with no business relationship to the account holder. FATF, 2021
“frequent deposits in cash”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. hawala and how does informal value transfer work, third-country bank accounts and how are they used, How are gold and commodities used to settle sanctioned trade
066 Brokers settle debts owed to one another by fulfilling the other's commercial obligations — paying a debt or an invoice of the same value — rather than by transferring funds. FATF, 2013
“settle accounts by fulfilling commercial obligations”
Source. FATF, The Role of Hawala and Other Similar Service Providers (2013). Read the source document.
Appears on. hawala and how does informal value transfer work, How are gold and commodities used to settle sanctioned trade, trade misinvoicing
067 Settlement between operators is made through value or cash outside the banking system, including by cash couriers, rather than through traceable transfers. FATF, 2013
“the use of cash couriers”
Source. FATF, The Role of Hawala and Other Similar Service Providers (2013). Read the source document.
Appears on. hawala and how does informal value transfer work, How are gold and commodities used to settle sanctioned trade
068 An operator's settlement commingles licit and illicit proceeds and nets obligations across jurisdictions, masking the individual fund transfers. FATF, 2013
“commingling of licit and illicit proceeds”
Source. FATF, The Role of Hawala and Other Similar Service Providers (2013). Read the source document.
Appears on. hawala and how does informal value transfer work, How are gold and commodities used to settle sanctioned trade, trade misinvoicing
069 The operator's business includes gold dealing alongside money transfer and currency exchange. FATF, 2013
“gold dealing”
Source. FATF, The Role of Hawala and Other Similar Service Providers (2013). Read the source document.
Appears on. hawala and how does informal value transfer work, How are gold and commodities used to settle sanctioned trade
070 An account shows an unexpectedly high number or value of transactions inconsistent with the client's stated business activity. FATF, 2021
“inconsistent with the stated business activity of the client”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. third-country bank accounts and how are they used, trade misinvoicing, How is correspondent banking used to evade sanctions
071 Cash deposits or other transactions are consistently just below the relevant reporting thresholds. FATF, 2021
“consistently just below relevant reporting thresholds”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. third-country bank accounts and how are they used, hawala and how does informal value transfer work
072 Transaction activity associated with a trade entity increases quickly and significantly in volume, then goes dormant after a short period. FATF, 2021
“goes dormant after a short period”
Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.
Appears on. a front company, a phantom shipment, third-country bank accounts and how are they used
073 A custodian holding a client's securities in an omnibus account does not screen the underlying account holders and beneficial owners against sanctions lists, relying only on the intermediary's own screening. ISSA, 2019
“screens transactions and holdings against lists of designated persons under”
Source. International Securities Services Association (ISSA), ISSA Financial Crime Compliance Principles for Securities Custody and Settlement (2019). Read the source document.
Appears on. How are omnibus securities accounts used to evade sanctions, How is correspondent banking used to evade sanctions
074 The underlying beneficial owner of assets held through an omnibus or nominee securities account is not identified or disclosed to the custodian holding the account, or to the counterparties clearing through it. ISSA, 2019
“screen both the underlying clients holding segregated accounts”
Source. International Securities Services Association (ISSA), ISSA Financial Crime Compliance Principles for Securities Custody and Settlement (2019). Read the source document.
Appears on. How are omnibus securities accounts used to evade sanctions
075 A securities intermediary does not periodically reassess whether maintaining an omnibus account for a particular account holder remains appropriate given its sanctions risk. ISSA, 2019
“assess their account holders periodically to determine the appropriateness”
Source. International Securities Services Association (ISSA), ISSA Financial Crime Compliance Principles for Securities Custody and Settlement (2019). Read the source document.
Appears on. How are omnibus securities accounts used to evade sanctions, How is correspondent banking used to evade sanctions
076 A firm has never run a test simulating access or a transaction from a sanctioned jurisdiction to confirm its own screening or geo-blocking controls actually stop it. OFAC, 2019
“are important tools to ensure the program is working as designed and identify weaknesses and deficiencies within a compliance program”
Source. OFAC, A Framework for OFAC Compliance Commitments (2019). Read the source document.
Appears on. What happens when sanctions-screening controls go untested
077 A screening or geo-blocking control was disabled for a software update, a migration or a vendor change, and nothing in the process required confirming it was switched back on. OFAC, 2026
“inadvertently failed to reenable the first-tier geo-blocking control after disabling it”
Source. OFAC, Enforcement release: TradeStation Securities, Inc. Settles with OFAC for $1,110,661 (2026). Read the source document.
Appears on. What happens when sanctions-screening controls go untested
078 An automated tool built to test that screening or geo-blocking controls actually work is quietly discontinued, disabled, or blocked by the firm's own infrastructure, and never replaced. OFAC, 2026
“discontinued the use of this tool in november 2021 without replacing it”
Source. OFAC, Enforcement release: TradeStation Securities, Inc. Settles with OFAC for $1,110,661 (2026). Read the source document.
Appears on. What happens when sanctions-screening controls go untested
079 A firm holds internet protocol address information about its users but does not use it to screen for and prevent potential sanctions violations. OFAC, 2021
“did not use the ip address information it collected”
Source. OFAC, Sanctions Compliance Guidance for the Virtual Currency Industry (2021). Read the source document.
Appears on. How is cryptocurrency used to evade sanctions, stablecoin settlement and why does it matter for sanctions, mixers and chain hopping
080 Geolocation tools and IP address blocking controls are not used to identify and prevent access from sanctioned jurisdictions. OFAC, 2021
“geolocation tools and ip address blocking controls”
Source. OFAC, Sanctions Compliance Guidance for the Virtual Currency Industry (2021). Read the source document.
Appears on. How is cryptocurrency used to evade sanctions, stablecoin settlement and why does it matter for sanctions
081 Customer information obtained at onboarding and through the relationship is not used to conduct due diligence sufficient to mitigate sanctions risk. OFAC, 2021
“know your customer (kyc) procedures”
Source. OFAC, Sanctions Compliance Guidance for the Virtual Currency Industry (2021). Read the source document.
Appears on. How is cryptocurrency used to evade sanctions, stablecoin settlement and why does it matter for sanctions, mixers and chain hopping
082 Value moves through anonymity-enhanced cryptocurrencies, mixers and tumblers, decentralised platforms or privacy wallets that reduce transparency and increase obfuscation of financial flows. FATF, 2021
“mixers and tumblers”
Source. FATF, Updated Guidance for a Risk-Based Approach to Virtual Assets and VASPs (2021). Read the source document.
Appears on. mixers and chain hopping, How is cryptocurrency used to evade sanctions, stablecoin settlement and why does it matter for sanctions
083 Products and services are used specifically because they enable or allow for reduced transparency and increased obfuscation of financial flows. FATF, 2021
“reduced transparency and increased obfuscation”
Source. FATF, Updated Guidance for a Risk-Based Approach to Virtual Assets and VASPs (2021). Read the source document.
Appears on. mixers and chain hopping, How is cryptocurrency used to evade sanctions
084 Transactions move through multiple exchange houses or trading companies, adding fees and costs at each step, in a pattern that does not reflect standard commercial practice. FinCEN, 2025
“move through multiple exchange houses and/or trading companies, adding additional fees and costs as the transactions progress”
Source. FinCEN, FinCEN Advisory FIN-2025-A002, Red Flags Associated with Iranian Shadow Banking Networks (2025). Read the source document.
Appears on. exchange-house and rahbar networks, hawala and how does informal value transfer work, third-country bank accounts and how are they used
085 An exchange house or trading company near the sanctioned country uses forged or falsified documents to hide the parties to transactions that rely on regional banks' correspondent relationships to reach US dollars. FinCEN, 2025
“uses forged or falsified documents to conceal the identity of parties involved in transactions”
Source. FinCEN, FinCEN Advisory FIN-2025-A002, Red Flags Associated with Iranian Shadow Banking Networks (2025). Read the source document.
Appears on. exchange-house and rahbar networks, How is correspondent banking used to evade sanctions, third-country bank accounts and how are they used
086 A general trading company registered in a UAE commercial free trade zone has opaque ownership, counterparties mostly in Singapore and Hong Kong, and accounts at several UAE banks. FinCEN, 2025
“general trading company registered in a commercial free trade zone in the UAE with opaque ownership”
Source. FinCEN, FinCEN Advisory FIN-2025-A002, Red Flags Associated with Iranian Shadow Banking Networks (2025). Read the source document.
Appears on. exchange-house and rahbar networks, a front company, third-country bank accounts and how are they used
087 A Hong Kong company banking through a Chinese non-resident account has little web presence or shares premises with similar companies, is newly incorporated, and sends large payments to UAE general trading companies for no clear purpose. FinCEN, 2025
“banks using a Chinese non-resident account, has little to no web presence”
Source. FinCEN, FinCEN Advisory FIN-2025-A002, Red Flags Associated with Iranian Shadow Banking Networks (2025). Read the source document.
Appears on. exchange-house and rahbar networks, a front company, shell company layering
088 Wire transfers or deposits carry no information, or incomplete information, about the source of funds, or do not match the customer's line of business, especially where entities in a high-risk jurisdiction are involved. FinCEN, 2025
“do not contain any information about the source of funds”
Source. FinCEN, FinCEN Advisory FIN-2025-A002, Red Flags Associated with Iranian Shadow Banking Networks (2025). Read the source document.
Appears on. exchange-house and rahbar networks, third-country bank accounts and how are they used
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