01

What a red flag indicates

A red flag points to a characteristic, behaviour or combination of facts that may be inconsistent with the expected profile. It does not automatically establish suspicion and does not replace contextual analysis.

02

The value of combinations

One fact may have a reasonable explanation. Several connected indicators — an opaque structure, high-risk geography, unexpected activity and contradictory documents — may materially change the assessment.

  • review the profile and purpose of the relationship;
  • reconstruct the sequence, amounts and counterparties;
  • assess explanations and quality of evidence;
  • document rationale, escalation and decision.
03

From alert to control

Quality is not measured by the number of alerts closed. It is measured by whether the process identifies relevant activity, avoids automatic conclusions and produces reconstructable decisions.

04

Why current sources matter

The Italian FIU explains that indicators and patterns are neither exhaustive nor prescriptive: the presence of an anomaly alone does not establish suspicion, while the absence of a listed indicator does not rule out risk. The UIF page includes the measure applicable from 1 January 2024 and subsequent communications: verify the relevant version at the review date.

05

Practical scenario

Illustrative scenario: a merchant with stable volumes triples its receipts and quickly transfers funds to two new counterparties. Growth and speed do not prove wrongdoing: they may reflect a new marketplace model or conceal pass-through activity. Compare the declared business with orders, settlement agreements, counterparties and the destination of funds.

Useful check: reconstruct a sequence of transactions, seek a verifiable legitimate explanation and record which evidence supports or contradicts it. Then explain closure or escalation under the applicable process.

Sources and references

Informational content. It does not replace an assessment of a specific case.

UIF — Anomaly indicators and patternsFATF — Risk-based approach
FROM CONTENT TO REVIEW

Move from the signal to the control.

See the support routes for control design, escalation, review and evidence.

Marco N. Pace
AUTHORMarco N. Pace

AML/CFT & Financial Crime professional

Profile and experience