TF Indicators

As you examine your institution’s data it is important to be able to identify potential red flags that could indicate suspicious activity that cannot be explained by reason.  Indicators help with developing a hypothesis that specific activities may require further investigation for financial or criminal activity or assessment of your client’s activities.

Indicators point to the possibility of specific activities occurring that can assist you with determining if there are reasonable grounds for further investigation.  It is notable that criminals may use one or a combination of indicators to commit a financial crime or an offence.   

The indicators should be weighed against the risk and context of the institution and the jurisdiction in which it operates.

General indicators for suspected terrorist financing activities include:

• Higher than expected volumes of small cash deposits. 

• Multiple transactions just under reporting thresholds. 

• Transactions where one of the parties is subject to frequent and relevant adverse news coverage. 

• Multiple transactions which are inconsistent with expected patterns. 

• Suspect appearance notes (old, covered in powder, having a peculiar smell). 

• Lack of economic explanation of transaction(s). • Transfers to accounts on which there are no other transactions. 

• There is more concern about speed than costs. 

• Activity was inconsistent with the customer’s profile. 

• Associations with multiple accounts under multiple names. 

• Deposits linked to gambling proceeds. 

• Depositing multiple large amounts of cash and receiving multiple cheques drawn on that account. 

• Elaborate movement of funds through different accounts. 

• Obtained loan and repaid balance in cash and frequent early repayments of loans. 

• Frequent deposits of winning gambling cheques followed by immediate withdrawal of funds in cash. 

• Frequent transfers indicated as loans sent from relatives. 

• Funds transferred to a charity fund. 

• High volume of transactions within a short period. 

• Large sums being credited into accounts from countries of concern. 

• Large cash deposits into company accounts. 

• Large amounts of cash from unexplained sources. 

• Multiple individuals sending funds to a single beneficiary. 

• Multiple cheques cashed into one personal bank account. 

• Structuring of cash deposits/withdrawals. 

Note: Indicators by themselves may not always be immediately indicative of suspect financial or criminal activity but together with other indicators and other factors, it might confirm TF suspicion or may give rise to further monitoring and due diligence.

First version was published on 17 June 2010

Amended version was published on 20 February 2020

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