Case snapshot: unexpected company transfer in a property transaction
Scene: London outskirts, property transaction – Thursday morning
Max reviewed the file over his second coffee. Everything had looked straightforward yesterday: a €1.2 million home, half financed by a mortgage, half by the sale of the clients’ previous property.
Then an alert popped up—€750,000 had just landed from a new company with no prior notice. Minutes later, an email from the client:
“We’ve had an old business debt repaid, so we won’t need the mortgage after all. Please complete tomorrow—urgent.”
Max frowned. A sudden funding shift, an unfamiliar company, external pressure to close fast.
He checked the company name—registered only two months earlier, with no active business filings.
Luc’s reply was immediate: “Freeze the workflow. Verify the origin, get documentation, escalate.”
Ella added, “If it’s legitimate, they’ll prove it. If it’s not, you’ve just stopped €750,000 of dirty money entering the property market.”
By afternoon, the clients withdrew “for personal reasons.” The deal collapsed.
For Max, it was confirmation that compliance doesn’t chase deadlines—it stops clocks when they start ticking too loudly.
The compliance team acted instantly, submitting the SAR to the Financial Intelligence Unit (FIU) to protect against potential money laundering.
Regulatory lens: ongoing monitoring and high-risk transaction review
Compliance is triggered by change, not just onboarding. Ongoing Monitoring (AMLR Art. 26) mandates that your system continuously checks all transactions against the customer's known risk profile.
Any transaction that is complex, unusually large, shows an unusual pattern, or lacks an apparent lawful purpose must be rigorously examined (AMLR Art. 34). Urgency, unexplained third-party funds, or a new source of wealth should immediately demand a refresh of CDD. Familiarity never substitutes for vigilance.
Final thought: urgency as a red flag in AML decision-making
Criminals run on speed. They weaponize deadlines and exploit the pressure to close a deal.
Remember that Urgency is a potential Red Flag, Not a Compliance Exemption.
Every dollar, euro, or token—regardless of the client’s reputation—must make sense. If an inflow is unexpected, unexplained, or routed through an unexplained third party, it is not justified by a timeline.
Speed clears deals; rigorous scrutiny prevents laundering. Choose scrutiny, every time.
