Client has multipleaccounts under asingle name ormultiple names with alarge number ofinteraccount to thirdparty transfers.Large numberof securitiestransactionsacross anumber ofjurisdictions.Maintains multipleaccounts, or maintainsaccounts in the namesof family members orcorporate entities withno apparent businessor other purpose.Lawenforcementsubpoenas.Customer engages inprearranged or othernon-competitivetrading, includingwash or cross tradesof illiquid securities.Refuses to identify alegitimate source forfunds or informationis false, misleadingor substantiallyincorrect.Client'sphonenumberprovided isdisconnected.Client attemptsto use differenttax id numberswith variationsof his or hername.Client makes adeposit followedby immediaterequest forwithdrawal ofthose same funds.Client is from anarea of thecountry thatgeographicallydoesn't makesense to contactthe given branchPurchases aninsurance product withunknown or unverifiablesource of funds, suchas cash, official checksor sequentiallynumbered moneyorders.Cancels aninsurancecontract anddirects funds toa third party."Structures" deposits,withdrawals orpurchase of monetaryinstruments below acertain amount to avoidreporting orrecordkeepingrequirements.Customerengages in tradingactivityinconsistent withtheir statedinvestmentobjective.Client exhibits unusualconcern about ourcompliance withgovernment reportingrequirements and AMLpolicies particularlyconcerning his or heridentity, or type ofbusiness and assets.Client becomessubject of anadverse newsreports (afteraccount openingprocess).Physicalcertificate istitled differentlythan theaccount.Unexplained highlevel of accountactivity with verylow levels ofsecuritiestransactions.Wire activity that isunexplained,repetitive, unusuallylarge or showsunusual patterns orwith no apparentbusiness purpose.Client is awalk in orobtained viabroker of theday.Customer'strading patternssuggest that heor she mayhave insideinformation.Customer withno discernablereason forusing thefirm's service.Client wishes toengage intransactions thatlack business senseor differ from statedinvestment strategy.Company hasexperiencedfrequent orcontinuouschanges in itsbusinessstructure.Client has multipleaccounts under asingle name ormultiple names with alarge number ofinteraccount to thirdparty transfers.Large numberof securitiestransactionsacross anumber ofjurisdictions.Maintains multipleaccounts, or maintainsaccounts in the namesof family members orcorporate entities withno apparent businessor other purpose.Lawenforcementsubpoenas.Customer engages inprearranged or othernon-competitivetrading, includingwash or cross tradesof illiquid securities.Refuses to identify alegitimate source forfunds or informationis false, misleadingor substantiallyincorrect.Client'sphonenumberprovided isdisconnected.Client attemptsto use differenttax id numberswith variationsof his or hername.Client makes adeposit followedby immediaterequest forwithdrawal ofthose same funds.Client is from anarea of thecountry thatgeographicallydoesn't makesense to contactthe given branchPurchases aninsurance product withunknown or unverifiablesource of funds, suchas cash, official checksor sequentiallynumbered moneyorders.Cancels aninsurancecontract anddirects funds toa third party."Structures" deposits,withdrawals orpurchase of monetaryinstruments below acertain amount to avoidreporting orrecordkeepingrequirements.Customerengages in tradingactivityinconsistent withtheir statedinvestmentobjective.Client exhibits unusualconcern about ourcompliance withgovernment reportingrequirements and AMLpolicies particularlyconcerning his or heridentity, or type ofbusiness and assets.Client becomessubject of anadverse newsreports (afteraccount openingprocess).Physicalcertificate istitled differentlythan theaccount.Unexplained highlevel of accountactivity with verylow levels ofsecuritiestransactions.Wire activity that isunexplained,repetitive, unusuallylarge or showsunusual patterns orwith no apparentbusiness purpose.Client is awalk in orobtained viabroker of theday.Customer'strading patternssuggest that heor she mayhave insideinformation.Customer withno discernablereason forusing thefirm's service.Client wishes toengage intransactions thatlack business senseor differ from statedinvestment strategy.Company hasexperiencedfrequent orcontinuouschanges in itsbusinessstructure.

AML Red Flags Bingo - Call List

(Print) Use this randomly generated list as your call list when playing the game. There is no need to say the BINGO column name. Place some kind of mark (like an X, a checkmark, a dot, tally mark, etc) on each cell as you announce it, to keep track. You can also cut out each item, place them in a bag and pull words from the bag.


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  1. Client has multiple accounts under a single name or multiple names with a large number of interaccount to third party transfers.
  2. Large number of securities transactions across a number of jurisdictions.
  3. Maintains multiple accounts, or maintains accounts in the names of family members or corporate entities with no apparent business or other purpose.
  4. Law enforcement subpoenas.
  5. Customer engages in prearranged or other non-competitive trading, including wash or cross trades of illiquid securities.
  6. Refuses to identify a legitimate source for funds or information is false, misleading or substantially incorrect.
  7. Client's phone number provided is disconnected.
  8. Client attempts to use different tax id numbers with variations of his or her name.
  9. Client makes a deposit followed by immediate request for withdrawal of those same funds.
  10. Client is from an area of the country that geographically doesn't make sense to contact the given branch
  11. Purchases an insurance product with unknown or unverifiable source of funds, such as cash, official checks or sequentially numbered money orders.
  12. Cancels an insurance contract and directs funds to a third party.
  13. "Structures" deposits, withdrawals or purchase of monetary instruments below a certain amount to avoid reporting or recordkeeping requirements.
  14. Customer engages in trading activity inconsistent with their stated investment objective.
  15. Client exhibits unusual concern about our compliance with government reporting requirements and AML policies particularly concerning his or her identity, or type of business and assets.
  16. Client becomes subject of an adverse news reports (after account opening process).
  17. Physical certificate is titled differently than the account.
  18. Unexplained high level of account activity with very low levels of securities transactions.
  19. Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent business purpose.
  20. Client is a walk in or obtained via broker of the day.
  21. Customer's trading patterns suggest that he or she may have inside information.
  22. Customer with no discernable reason for using the firm's service.
  23. Client wishes to engage in transactions that lack business sense or differ from stated investment strategy.
  24. Company has experienced frequent or continuous changes in its business structure.