Suspicious activity is behavior or a transaction pattern that may indicate financial crime, fraud or an attempt to evade controls. Suspicion is based on context and indicators, not only transaction size.
Which indicators can require review?
- Activity inconsistent with the customer profile
- Unexplained third-party payments
- Rapid movement of funds
- Structuring around limits
- Unusual jurisdictions or counterparties
- False, altered or evasive information
Does an alert prove wrongdoing?
No. An alert identifies activity for assessment. Reviewers should evaluate the transaction, customer, explanation and supporting evidence before deciding.
How should a business respond?
Follow internal escalation, preserve records, restrict access to sensitive review information and comply with applicable reporting and confidentiality rules. Staff should not alert a subject improperly.
Suspicious activity vs. payment fraud
Payment fraud involves unauthorized or deceptive conduct. Suspicious activity is broader and can indicate money laundering, sanctions evasion or other risk even when no fraud is confirmed.
What should the review record contain?
Document the trigger, evidence, analysis, decision, approver and resulting action. Avoid unsupported conclusions or discriminatory assumptions.
