Customer withno discernablereason forusing thefirm's service.Client makes adeposit followedby immediaterequest forwithdrawal ofthose same funds.Physicalcertificate istitled differentlythan theaccount.Client is from anarea of thecountry thatgeographicallydoesn't makesense to contactthe given branchUnexplained highlevel of accountactivity with verylow levels ofsecuritiestransactions.Client wishes toengage intransactions thatlack business senseor differ from statedinvestment strategy.Lawenforcementsubpoenas.Client becomessubject of anadverse newsreports (afteraccount openingprocess)."Structures" deposits,withdrawals orpurchase of monetaryinstruments below acertain amount to avoidreporting orrecordkeepingrequirements.Customer'strading patternssuggest that heor she mayhave insideinformation.Purchases aninsurance product withunknown or unverifiablesource of funds, suchas cash, official checksor sequentiallynumbered moneyorders.Client is awalk in orobtained viabroker of theday.Refuses to identify alegitimate source forfunds or informationis false, misleadingor substantiallyincorrect.Client attemptsto use differenttax id numberswith variationsof his or hername.Client exhibits unusualconcern about ourcompliance withgovernment reportingrequirements and AMLpolicies particularlyconcerning his or heridentity, or type ofbusiness and assets.Large numberof securitiestransactionsacross anumber ofjurisdictions.Customer engages inprearranged or othernon-competitivetrading, includingwash or cross tradesof illiquid securities.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'sphonenumberprovided isdisconnected.Maintains multipleaccounts, or maintainsaccounts in the namesof family members orcorporate entities withno apparent businessor other purpose.Company hasexperiencedfrequent orcontinuouschanges in itsbusinessstructure.Cancels aninsurancecontract anddirects funds toa third party.Customerengages in tradingactivityinconsistent withtheir statedinvestmentobjective.Customer withno discernablereason forusing thefirm's service.Client makes adeposit followedby immediaterequest forwithdrawal ofthose same funds.Physicalcertificate istitled differentlythan theaccount.Client is from anarea of thecountry thatgeographicallydoesn't makesense to contactthe given branchUnexplained highlevel of accountactivity with verylow levels ofsecuritiestransactions.Client wishes toengage intransactions thatlack business senseor differ from statedinvestment strategy.Lawenforcementsubpoenas.Client becomessubject of anadverse newsreports (afteraccount openingprocess)."Structures" deposits,withdrawals orpurchase of monetaryinstruments below acertain amount to avoidreporting orrecordkeepingrequirements.Customer'strading patternssuggest that heor she mayhave insideinformation.Purchases aninsurance product withunknown or unverifiablesource of funds, suchas cash, official checksor sequentiallynumbered moneyorders.Client is awalk in orobtained viabroker of theday.Refuses to identify alegitimate source forfunds or informationis false, misleadingor substantiallyincorrect.Client attemptsto use differenttax id numberswith variationsof his or hername.Client exhibits unusualconcern about ourcompliance withgovernment reportingrequirements and AMLpolicies particularlyconcerning his or heridentity, or type ofbusiness and assets.Large numberof securitiestransactionsacross anumber ofjurisdictions.Customer engages inprearranged or othernon-competitivetrading, includingwash or cross tradesof illiquid securities.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'sphonenumberprovided isdisconnected.Maintains multipleaccounts, or maintainsaccounts in the namesof family members orcorporate entities withno apparent businessor other purpose.Company hasexperiencedfrequent orcontinuouschanges in itsbusinessstructure.Cancels aninsurancecontract anddirects funds toa third party.Customerengages in tradingactivityinconsistent withtheir statedinvestmentobjective.

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.


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