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50 Standard AML Models Your Firm Should be Running  

With the proliferation of anti-money-laundering (AML) applications that are basically black boxes, it can be difficult to verify that your firm is using an appropriate set of models to effectively combat money-laundering and terrorist-financing (TF) to meet regulators’ requirements. To assist validating your platform or a new platform that you may be considering, we have created a list of 50 standard AML models that you should expect to be included in an application.

 

Note: Every financial firm has different product and risk profiles that requires a customized set of AML models, but we commonly recommend the 50 models listed below be included in a standard AML/TF platform.

 

  1. USD 10,000 limit - Deposits

  2. EUR 10,000 limit - Deposits

  3. USD 10,000 limit - Withdrawals

  4. EUR 10,000 limit - Withdrawals

  5. USD 2000 - <10,000 limit - Withdrawals with suspicious activity

  6. Sanctioned Countries - Payment Origination

  7. Sanctioned Countries - Payment Receipt

  8. Sanctioned Businesses and Individuals

  9. Air/Bus/Boat Tickets purchased for secondary recipients

  10. Hotel rooms purchased for secondary recipients

  11. Wire remittances received without opening of a bank account

  12. Source of funds is crowd funding site

  13. High percentage of account balance or deposits paid to Non-Profit Organizations (NPO)

  14. Multiple, on-going purchases of phone cards or cell phones

  15. Multiple, on-going purchases of gift/retail cards

  16. NPO name similar to well-known, trusted NPO

  17. NPO funds usage for personal expenses of beneficial owner (BO)

  18. Travel expenses to sanctioned countries

  19. Media stories indicating criminal/terrorist activity

  20. BO links to unregistered NPO

  21. Multiple daily deposits below USD/EUR 10,000 limit

  22. Vague or undefined source of income (deposits)

  23. Steady payments to multiple individuals

  24. Payments on recruitment material (flyers, webpage development)

  25. Payments to rent meeting locations

  26. Payments for multiple home rentals

  27. Payments for multiple auto rentals

  28. Deposits primarily from NPO account

  29. Large deposits to NPO officer personal accounts

  30. Deposits from same source into accounts with related individuals/entities

  31. Multiple hops deposit

  32. Payment of expenses (e.g. medical) not related to account holder

  33. Deposits followed immediately by withdrawals leading to average low balance

  34. Multiple withdrawals from same account in multiple countries

  35. Deposits from source involved with high risk product

  36. BO links to unregistered NPO

  37. BO or BO relation becomes politically exposed person (PEP)

  38. PEP BO account average balance increases specified % in a short specified period

  39. Correspondent account activity increases

  40. Correspondent account deposits/withdrawals increase specified %

  41. Wire information does not correlate to prior/expected information

  42. Source of funds is sale of virtual currency

  43. Source of funds from unexpected product per business description

  44. Daily sum of deposits just below reporting guidelines

  45. Income from business % higher/lower than expected normal income

  46. Casino transactions % above/below standard average deposits/withdrawals

  47. Purchase/Sale of real estate by Real Estate agent on behalf of customer

  48. Precious metals/stones transactions % above/below standard average deposits/withdrawals

  49. Legal professionals or accountants with non-standard transactions 

  50. Trust and company service providers with non-standard transactions

At Clovis Technologies, we know that by bringing together people with an understanding of problems from different viewpoints, and integrating their experiences and knowledge, we develop the most innovative solutions.

 

Contact us today to find out how a partnership with Clovis Technologies can help you develop and implement truly innovative solutions to some of your toughest problems.