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Clients
who appear to be living well beyond their means
in the light of their employment, profession or
business. |
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Clients
conducting business transactions inconsistent with
the nature of their employment, profession or business
or where business activity is inconsistent with
industry average or financial ratios. |
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Client
requests anonymity. |
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Client
is unconcerned about fees to be paid in respect
to an aborted transaction |
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Client
wants you to coordinate international transactions,
including currency exchanges, or to coordinate cross-border
movement of funds, when this type of transaction
in inconsistent with the ordinary business practice
of the client. |
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Client
requests you to establish a nominee company or trust
for deposit of funds, when this type of transaction
is inconsistent with the ordinary business practice
of the client. |
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Client
makes unusual requests for placement of funds into
trust accounts for safekeeping. |
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Client
refuses to discuss the business purpose of the transaction. |
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Client
seeks to obtain trust account information and is
prepared to pay unusually high fees to use this
information and account. |
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Client
offers to pay a much higher fee than is usually
charged or than you quoted to get assistance on
a transaction involving large sums. |
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Client
has cheques inconsistent with sales. |
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Client
has a history of changing auditors/legal counsel. |
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Client
is uncertain as to the location of the company records. |
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Company
has no employees, which is unusual for the type
of business. |
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Company
is paying unusual consulting or similar fees to
offshore companies. |
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Company
records consistently reflects sales at less than
cost, but company continues in business without
reasonable explanation of the continued loss. |
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Company
makes large payments/transfers to subsidiaries or
other controlled companies, that are not within
the normal course of business. |
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Examination
of source documents shows misstatements of business
activity that cannot be readily traced through the
company books. |
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Company
is undertaking activities inconsistent with its
Commercial Registration license and Memorandum &
Articles of Association Company acquires large consumer
assets (i.e boats, luxury automobiles, personal
residences etc.) when this is inconsistent with
the ordinary practice of the company or industry. |
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Company
is invoiced by organizations located in territories
that do not have adequate anti-money laundering
systems, or are known to be highly secretive banking
and tax havens. Please see
http://www.oecd.org/daf/fa/first_en.htm
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