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Anti-Money Laundering: Spotting and Reporting Red Flags

Introduces AML obligations, customer due diligence steps, common suspicious activity patterns, and the correct internal escalation path for raising concerns.
LBy Leadde Updated August 23, 2026

What a Money Laundering Red Flag Looks Like in Practice

A red flag is rarely a single suspicious act; it is a pattern that does not fit the customer. Transactions structured just below a reporting threshold, a business whose turnover does not match its premises, a customer unusually incurious about cost: each is unremarkable alone and meaningful in combination.

That combinatorial quality is what makes this hard to train. Staff taught a list of indicators look for the indicators and miss the mismatch, which is the actual signal, and the mismatch is only visible to the person who knows what normal looks like for that customer. One thing to keep off screen is thresholds and detection logic: publishing the amounts and rules that trigger review tells anyone who watches exactly how to stay underneath them.

The template covers it in ten scenes: two on why patterns rather than acts matter, two on customer due diligence and what normal looks like, three on the red flag categories staff most often encounter, one on what must never be said to the customer, one on the internal escalation path, and one on the confidentiality that follows a report.

How to Make Escalation Something Staff Actually Do

The failure in this area is almost never recognition; it is escalation. Staff notice something, decide it is probably nothing, and do not want to accuse a customer they have a relationship with. The training has to remove the sense that reporting is an accusation.

Say that a report is not an allegation

Say that a report is not an allegation

Escalation is a request for someone else to look. Framing it that way removes the largest barrier in the entire process.

Make tipping off a named prohibition

Staff will otherwise warn a customer out of ordinary courtesy. This is the single most damaging thing an untrained employee can do here, and it needs its own scene.

Teach normal before abnormal

A pattern only looks wrong against an expectation. Due diligence is what builds the expectation, which is why it belongs before the red flag list rather than after it.

Route it to a person, not a form

Named role, named channel, same day. Ambiguity in the route is where escalations quietly stop.

Point it at the AML policy your compliance team maintains

Upload the AML policy, the customer due diligence procedure, or the anonymised escalation examples from your assurance review as PDF, DOC, DOCX, PPTX, or TXT, up to 200 MB. Every scene returns editable, and the file itself is untouched.

Confirming It Reached the People Who Need It

Build the version for the role that meets customers

Build the version for the role that meets customers

Onboarding, relationship management, and operations see different signals. A single general version trains nobody in what they will actually encounter.

Keep examples anonymised and non-identifying

Keep examples anonymised and non-identifying

Real cases are the most instructive material available and the most dangerous to reuse. Every detail that could identify a customer or a case has to be changed before it goes near the project.

Check completion before the assurance review, not after

Check completion before the assurance review, not after

Open the analytics dashboard once it is issued and confirm the required roles finished it. On a topic where an assurance reviewer will ask, knowing early is the difference between a gap and a finding.

AML Red Flag FAQ

A mismatch with what is known about the customer. An unusual amount from a customer whose business explains it is not a flag; an ordinary amount that does not fit the stated activity is.

No. Tipping off is prohibited, and an ordinary clarifying question can constitute it. The correct action is to escalate internally and continue serving the customer normally.

A designated function assesses it and decides whether an external report is required. Staff are not required to reach a conclusion, and are usually not told the outcome, which is a confidentiality requirement rather than a lack of feedback.

Not on its own. Leadde produces the video and does not certify a programme, track attestation, or constitute evidence of compliance; it maintains SOC 2, ISO 42001, and GDPR alignment for its own operations. Your compliance function decides what satisfies the obligation.

Escalate It Without Accusing Anyone

Start from the AML policy your compliance team maintains; everything stays editable right up to the next assurance review.

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