Some Red Flags

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Most compliance practitioners have heard the term “Red Flags.” Red Flags are generally defined as circumstances which could place a reasonable person on notice that illegal or improper conduct has or may occur. A Red Flags does not mean that an action or transaction should immediately be terminated. It does mean that you should engage in an appropriate level of additional due diligence and investigation before moving forward.

In his blog posting yesterday entitled ”On Anti-Money Laundering“, our colleague Howard Sklar, discussed a new anti-money laundering initiative from the Asset Forfeiture and Money Laundering Section of the Department of Justice. Howard has previously spoken of “compliance convergence” or the merging of control programs such as anti-bribery and anti-corruption with anti-money laundering. Inspired by Howard’s post and his use of “compliance convergence” this post will list some possible Red Flags that you should consider in three control areas: anti-bribery and and anti-corruption; anti-money laundering and with a nod towards the ever changing economic sanctions being levied against Libya, Red Flags regarding international economic sanctions.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

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