INV-CB-003Critical Risk
customer behavior
Red Flag
Client introduces another prospective investor who is a PEP or sanctioned individual, and attempts to facilitate account opening by vouching for them or offering to co-sign.
Industry
Investment Advisers
Transaction Type
wire
Customer Type
individual
Category
Regulatory Source
Document:Kleptocracy Advisory
Type:FinCEN Advisory
CFR Citation:31 CFR §1010.630
SAR Category:PEP concern
FinCEN Key Term:PEP Introduction
Last Verified:2026-04-15
This red flag is provided for informational and educational purposes only. It is not legal, regulatory, or compliance advice. Always consult the official source document and a qualified compliance professional for guidance specific to your situation.