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

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