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👉 Useful tips on how NOT to tip-off your client 👈 Tipping off is prohibited in most #AML regulations and can have serious consequences for the individual who commits this offense. ❌ 𝐖𝐡𝐚𝐭 𝐢𝐬 𝐭𝐢𝐩𝐩𝐢𝐧𝐠-𝐨𝐟𝐟? Tipping-off is when an employee notifies a customer that a Suspicious Transaction/Activity Report (STR/SAR) was filed with the relevant Financial Intelligence Unit (FIU) or that a customer is under a #moneylaundering (ML) investigation. 🔎 𝐓𝐢𝐩𝐬 𝐭𝐨 𝐚𝐯𝐨𝐢𝐝 𝐭𝐢𝐩𝐩𝐢𝐧𝐠-𝐨𝐟𝐟 𝐲𝐨𝐮𝐫 𝐜𝐥𝐢𝐞𝐧𝐭 What happens if a company needs more information on the nature of specific transactions as part of identifying suspicious transactions ❓ Some good practices when you communicate with the customer: 💡 Use language that makes the request sound standard and part of regular procedures. 💡 Instead of singling out the specific transaction, make a general request for updated information or documents from all clients. 💡 Mention that periodic compliance reviews are part of standard procedures. Explain that you are conducting routine checks to ensure that client information is up-to-date and in compliance with regulations. 💡 If possible, break down the information request into stages. Start with basic or general information before progressing to more specific details. This gradual approach can appear less intrusive. 💡 Refrain from mentioning specific details about the transaction that triggered the request. Keep your communication focused on the need for updated information without divulging unnecessary specifics. 💡 Clearly outline what information is required and provide straightforward instructions on how the client can submit the requested details. What other tips would you recommend to avoid tipping-off your client?
Useful tips Anna Stylianou. I would also add not telling the customer who is making this request for more information. Such as the AML unit or a specific law enforcement agency. Believe it or not, that has even come up over wiretaps!
So nothing. Zero. The client facing person should not be the MLRO. The client facing should use higher authority negotiation tactics. “It’s not me, it’s in the system etc etc etc” Smile and say no until your tongue falls out!
Tipping off is an offence which comes with huge fine and as such when requesting for information from clients under STR/SAR, those information should seem as periodic customer updates.
Barbara Simeon
5mo
This will help me to incorporate this in my ML/TF refresher sessions. Thanks for sharing 👍 😊
Worth sharing, Anna.
Anna, very helpful tips. Thank you!
Thank you for sharing!
AML/KYC Analyst| Data Analyst | Investor Categorisation
5moThanks a lot for these tips, really insightful. You just made communicating and requesting for additional information from clients a lot easier. And better still, how to identify tipping off within employee-client correspondence.💯