INV-TM-005Critical Risk

transaction monitoring

Red Flag

Client requests that dividends, interest, or capital gains be paid to a different account or payee than the original funding source, with no documented gift, family, or legal reason for the diversion.

Industry
Investment Advisers
Transaction Type
wire
Customer Type
individual
Category
transaction monitoring
Regulatory Source
Document:FIN-2015-G001 Investment Advisers
Type:FinCEN Guidance
CFR Citation:31 CFR §1024.220
SAR Category:Suspicious activity
FinCEN Key Term:Income Diversion
Last Verified:2026-04-15
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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.

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