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

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