Workplace scenarios

Scenario 1: The deposits just under the threshold

A bookkeeper notices that a client's takings arrive as frequent cash deposits, each one just below the level that would trigger extra verification, several times a week. The client's stated turnover does not obviously support that volume of cash, and when the pattern is mentioned in passing, the client changes the subject.

What good looks like: the bookkeeper recognises this as possible structuring, sometimes called smurfing, where a large amount is deliberately broken into smaller transactions to stay under thresholds. She does not accuse the client or investigate further herself. She notes what she has observed and raises it promptly through her firm's internal process, usually to the MLRO, while continuing to deal with the client normally and saying nothing that could alert them.

Scenario 2: The urgent offshore structure

A prospective client asks a professional services firm to set up a UK company owned through a chain of overseas entities. He is vague about who ultimately owns the structure, offers no commercial reason for its complexity, wants everything completed within days, and becomes irritable when asked routine source-of-funds questions.

What good looks like: the firm treats this as a case for enhanced due diligence, not standard checks. It insists on identifying the ultimate beneficial owner and understanding the source of funds before proceeding, with senior sign-off on the decision. Urgency, complexity with no rationale, and resistance to routine questions are each red flags, and together they justify slowing down. If the answers never come, the firm declines the work and considers an internal report.

Scenario 3: The quiet word

A relationship manager has reported a suspicion about a long-standing customer to the MLRO. Feeling guilty, he considers phoning the customer to give them a chance to explain, or at least hinting that they should get their paperwork in order.

What good looks like: he says nothing. Alerting a customer, directly or indirectly, that a report has been made or that they are under scrutiny is tipping off, which is a criminal offence, because it could let them move assets or destroy evidence. His job ended when he reported his suspicion internally. He continues to serve the customer exactly as normal and leaves the formal reporting decision to the MLRO.

Scenario 4: The in-and-out account

A business customer's account receives a large transfer from a third party with no connection to the customer's known trade. Within days, the customer instructs that most of it be sent on to an overseas account, giving only a vague explanation about helping a business partner.

What good looks like: staff recognise two classic red flags together: funds moving rapidly in and straight back out with little economic sense, and third-party payments with no adequate explanation. The team asks for a credible explanation, and when none is given, raises the concern internally. Nobody needs proof that laundering is occurring; reasonable suspicion is enough to trigger the internal report.